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. 2024 20244101F — I.R.C. Section 6103 PDF 20242301F — (“Taxpayer”) – Termination of Forward Rate Agreements PDF 2023 20234801F — Section 168(k) First-Year Depreciation Deduction PDF 20234101F — Disallowance of Section 168(k) Additional First-Year Allowance for Depreciation for “Excepted Trade or Business”(2021) PDF 20233201F — Disallowance of non-cash charitable deduction PDF 20231601F — Method Used to Compute PDF 2022 20224001F — Character Payment of Royalties PDF 20223401F — Section 41 Research Credit Claims PDF 20223302F — File Form 5471 PDF 20223301F — Section 461s PDF 20221101F — Project 990-N Compliance Project PDF 2021 20214101F — I.R.C. § 41 Research Credit Refund Claims PDF 20212501F — Section 41 Research Credit Claims PDF 20212502F — Purported Transfer of LLC Units to Tax-Exempt Entity and Related Transactions PDF 20211701F — Captive Insurance Promotion Notice 2016-66 PDF 20211601F — Captive Insurance Promotion Notice 2016-66 PDF 20211602F — IRS Notice 2016-66, Transaction of Interest – Section 831(b) Micro-Captive Transactions PDF 20211603F — Transaction of Interest – Section 831(b) Micro-Captive Transactions Notice 2016-66 PDF 20211603F — Transaction of Interest – Section 831(b) Micro-Captive Transactions Notice 2016-66 PDF 20211603F — Transaction of Interest – Section 831(b) Micro-Captive Transactions Notice 2016-66 PDF 20211606F — Captive Insurance Arrangement and Notice 2016-66 PDF 2020 20205301F — Internal Revenue Code Section 59(e) election PDF 20205201F — Treas. Reg. § 301.9100-3 Relief for Applications for Exemption PDF 20204201F — § 1.704-3(a)(10)(i) anti-abuse rule PDF 20202501F — NOL Carryforward Audit in Taxable Year PDF 20200801F — Statute of Limitations for IRC § 4980H PDF 2018-2019 Legal Advice Issued by Field Attorneys in 2019 Legal Advice Issued by Field Attorneys in 2018 2016-2017 Legal Advice Issued by Field Attorneys in 2017 Legal Advice Issued by Field Attorneys in 2016 2014-2015 Legal Advice Issued by Field Attorneys in 2015 Legal Advice Issued by Field Attorneys in 2014 2012-2013 Legal Advice Issued by Field Attorneys in 2013 Legal Advice Issued by Field Attorneys in 2012 2010-2011 Legal Advice Issued by Field Attorneys in 2011 Legal Advice Issued by Field Attorneys in 2010 2008-2009 Legal Advice Issued by Field Attorneys in 2009 Legal Advice Issued by Field Attorneys in 2008 2005-2007 Legal Advice Issued by Field Attorneys in 2007 Legal Advice Issued by Field Attorneys in 2006 Legal Advice Issued by Field Attorneys in 2005 2003-2004 Legal Advice Issued by Field Attorneys in 2004 Legal Advice Issued by Field Attorneys in 2003