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. 2011 20115101F — Temporary Taking of Two Properties Attributable to an Involuntary Conversion PDF 20115001F — Non-deductibility of Certain Corporate Costs PDF 20114901F — Attorney Fees Incurred to Defend Against Patent Infringement Claims and to Investigate Patents PDF 20114704F — Conversion of Penalty Portion of Settlement Allocation in Class Action Lawsuit to Wages PDF 20114703F — Cost Recovery of Capitalized Attorney Fees Incurred to Defend Against Patent Infringement Claims and to Investigate Patents PDF 20114702F — LIFO Conformity Violation PDF 20114701F — Examination of Previously examined Year in Connection with Net Operating Loss Carryback PDF 20113901F — Qualifying Small Power Production Facility PDF 20113802F — Income Recognition from Sales of Gift Checks by a Membership Special Entity PDF 20113801F — Contribution of Inventory Approaching "best by" Date PDF 20112701F — Bank Enterprise Award payment received from the U.S. Department of the Treasury Community Development Financial Institutions Fund PDF 20111701F — Tax Matters Partner's Authority to Sign a Form 872-P PDF 20111101F — Deductibility of Purportedly Worthless Goodwill PDF 2010 20105101F — Retroactive Re-classification of Purchases into PURPIMS PDF 20105001F — Foreign Tax Credit PDF 20103901F — Graduate Level Tuition Waivers as Taxable Fringe Benefits PDF 20103101F — Patronage Dividend Deduction PDF 20103002F — Income Tax Adjustment for Certain Payments or Discounts made in Violation of the Anti-Kickback Act — 41 U.S.C. sections 51-58 PDF 20103001F — TEFRA Partnership Issues PDF 20102901F — Request for Legal Advice on Procedures when Dealing with Frivolous Business Returns PDF 20102602F — Application of Uniform Capitalization Rules of Section 263A to Ending Physical Grain Inventory Held for Resale PDF 20102601F — Wrongful Levy PDF 20101502F — I.R.C. Section 833(b) Special Deduction PDF 20101501F — Housing Authority Mutual Help Homeownership Opportunity Program PDF 20100902F — I.R.C. Section 482 Acquisition Buy-in PDF 20100901F — Use of Gift Card Disregarded Entity PDF 20100502F — Use of Tax Book Value to Establish Fair Market Value of Assets PDF 20100501F — Effect of Closing Agreement on Taxpayer's LIFO Definition of an Item PDF 20100301F — Tax Treatment of Post-Spinoff Payments PDF Related topic Legal Advice Issued by Field Attorneys
