These documents are prepared by field attorneys in the Office of Chief Counsel, reviewed by an Associate Office, and subsequently issued to field or service center campus employees of the Internal Revenue Service. Note: These items cannot be used or cited as precedent. 2007 20075201F — Taxation of License Agreement PDF 20075001F — Request for Advice Regarding Allowance of Application for Tentative Refund Based On Claim of Right Adjustment Pursuant to I.R.C. section 1341 PDF 20074901F — Gain Recognition Agreements and Reasonable Cause Exceptions under Sec. 367 PDF 20074401F — Newspaper Mastheads — Advertiser Accounts — and Subscriber Accounts under Section 1031 PDF 20073802F — Advice on the Time for Making the I.R.C. Section 847 Election PDF 20073801F — Theft Loss Advisory PDF 20073301F — Deductibility of a clawback payment claimed as a royalty payment PDF 20072502F — Application of Rev. Rul. 89-96 to subject Retroactive Reinsurance Transaction PDF 20072501F — Refund of Sec. 847 Special Estimated Tax Payments (SETP) Paid in Prior Years PDF 20072201F — Deductibility of 2 1/2% Additional Tax under California Rev. and Tax. Code Sec. 17085 PDF 20072101F — Television Network Affiliation Agreement Issues PDF 20071801F — Tax Treatment of Various Services Related to Environmental Remediation Liabilities PDF 20071702F — I.R.C. Section 41(d)(4): Qualified Research; Activities after the beginning of commercial production PDF 20071701F — Consent to Extend Statute of Limitations on Assessment; Execution of Waiver of Restrictions on Assessment PDF 20071101F — Valuation of Excess Parts Inventory PDF 20070801F — Issues relating to Agreement to Special Lien PDF 20070601F — Application of Rev. Rul. 2001-8 to Rebates PDF 20070401F — Temporary Markdowns Under the Lower-of-Cost-or-Market Inventory Method PDF 2006 20065101F — Amended return with tax increase and NOL carryback PDF 20064602F — Form 5471 Filing and Penalty for Failure to File PDF 20064601F — Worthlessness of partnership interests in and loans to PDF 20064401F — Redemption of Stock PDF 20064301F — Calculation of LIFO Index (I.R.C. Sec. 472) PDF 20062801F — Prepayment of Electricity Discounts under Amended Power Purchase Agreement PDF 20062701F — Assertion of penalties for failure to file information returns with respect to certain foreign entities PDF 20062201F — PORC Audit Issues PDF 20061703F — Advice regarding substantial omission and listed transaction exceptions (I.R.C. Sec. 6501) PDF 20061702F — Priority of estate tax lien PDF 20061701F — Vacation and bonus pay employment tax accrual PDF 20060902F — Collection After Assessment PDF 20060901F — Taxability of Payments to Recipients Under a State Fund PDF 2005 20055203F — Deductibility of research and experimental expenditures under I.R.C. § 174 PDF 20055202F — Tax treatment of Continued Dumping and Subsidy Offset Act (CDSOA) subsidy PDF 20055201F — Theft Loss Advisory PDF 20052501F — Need for a new Form 8655 when EIN merges occur PDF 20051802F — Treatment of Certain Losses PDF 20051801F — Duplicated Loss PDF 20051001F — Books and Records Income Allocation Method under I.R.C. § 863 PDF 20050203F — Whether the subject sale and acquisition of property qualifies for like-kind exchange treatment under I.R.C. §1031 PDF 20050202F — The effect of I.R.C. § 6213(f) on calculations of the last date to file a petition with the Tax Court upon dismissal or discharge from bankruptcy and the statute of limitations date for making an assessment of tax PDF 20050201F — Advisory Opinion on Collection of Taxes PDF Related topic Legal Advice Issued by Field Attorneys
