Statement of Principles of Internal Revenue Tax Finding List of Previously Published Rulings Finding List of Obsolete Published Rulings xi to Alcohol, Tobacco, and Firearms 5 Part II.-Rulings and Decisions Under the Internal Revenue Code of 1939 and Other Laws, except those pertaining to Alcohol, Tobacco, and Part IV.—Treaties and Tax Legislation Subpart A.—Tax Conventions 434 Subpart C.-Committee Reports 446 For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402 Price: Cloth-$8.30. Stock Number 4804-00696 The Service also has the responsibility of apply. examining officers when they have merit, never arbitrarily or for trading purposes. At the same time, the examining officer should never hesitate to raise a meritorious issue. It is also important that care be exercised not to raise an issue or to The function of the Internal Revenue Service is to With this in mind, it is the duty of the Service to carry out that policy by correctly applying the laws enacted by Congress; to determine the reason- able meaning of various Code provisions in light of the Congressional purpose in enacting them; and to perform this work in a fair and impartial manner, with neither a government nor a tax- At the heart of administration is interpretation of the Code. It is the responsibility of each person in the Service, charged with the duty of interpreting the law, to try to find the true meaning of the statutory provision and not to adopt a strained construction in the belief that he is “protecting the revenue." The revenue is properly protected Administration should be both reasonable and vigorous. It should be conducted with as little delay as possible and with great courtesy and con- siderateness. It should never try to overreach, and should be reasonable within the bounds of law and sound administration. It should, however, be vigorous in requiring compliance with law and it These principles of tax administration were previously published Introduction do not have the force and effect of Treasury De- The Internal Revenue Bulletin is the authoritative Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, industry regulations appear- ing in internal management documents and statements of internal practices and procedures that affect the rights and duties of taxpayers are Revenue Rulings represent the conclusions of the Service on the application of the law to the entire state of facts involved. In those that are based on positions taken in rulings to taxpayers or techni- cal advice to service field offices, identifying de- tails and confidential information are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements, such as 18 U.S.C. 1905 and 26 U.S.C. 7213 concerning dis- closure of information obtained from members of Rulings and procedures reported in the Bulletin Cumulative Bulletin 1973-2 is a consolidation of all items of a permanent nature published in the weekly Bulletins 1973-27 through 1973-53 for the period of July 1 through December 31, 1973. It includes a cumulative list of announcements The Bulletin Index-Digest System, a research and may be obtained from the Superintendent of Documents on a subscription basis. It consists of four Services: 1-Income Tax, 2-Estate and Gift Taxes, 3—Employment Taxes, and 4 Excise Taxes. Each Service consists of a basic volume and a cumulative supplement that provide (1) find- ing lists of items published in the Bulletin, (2) digests of Revenue Rulings, Revenue Procedures, and other published items, and (3) topical indexes of Public Laws, Treasury Decisions, and Tax Con- ventions. The contents of this publication are not copyrighted and may be Foreword The Internal Revenue Cumulative Bulletin is prepared in five parts as follows: Part 1.—1954 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1954 other than those pertaining to alcohol, tobacco, and firearms. Arrangement is sequential according to Code and regulations sections. The Code section is shown at the top of each page. Part 11.-1939 Code. This part includes decisions based on provisions of the Internal Revenue Code of 1939 and other laws, except those pertaining to alcohol, tobacco, and firearms. Part III.- Reserved. (This part contained all matters pertaining to alcohol, tobacco, firearms, and explosives prior to the transfer of the Alcohol, Tobacco and Firearms Division from the Internal Revenue Service to the Bureau of Alcohol, Tobacco and Firearms, Department of the Treasury, effective July 1, 1972, Treasury Department Order No. 221, 1972-2 C.B. 899.) Part IV.—Treaties and Tax Legislation. This part is divided into three subparts as follows: Subpart A, Revenue Ruling related to Tax Conventions; Subpart B, Legislation; Subpart C, Committee Reports. House, Senate, and Conference Committee Reports printed in the Bulletin do not include the portion entitled "Changes in Existing Law." Part V.-Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross-references to these subjects are contained in the other parts and Subparts. Included in this Part is a list of persons disbarred or suspended from practice before the Internal Revenue Service. The synopses preceding Revenue Rulings, Revenue Procedures, and Court Decisions are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. Abbreviations The following abbreviations in current use and formerly used will appear in material published in the Bulletin. A, B, C, etc. The names of individuals. A.R.R. Committee on Appeals and Review recom mendation. A.T. Alcohol and tobacco tax ruling. B.T.A. Board of Tax Appeals. C.B. Cumulative Bulletin. C.F.R. Code of Federal Regulations. C.T. Carriers Taxing Act of 1937. Ct. D. Court Decision. Del. Order. Delegation Order. D.C. Treasury Department circular. DISC Domestic International Sales Corporations. E.O. Executive Order. E.T. Estate and gift tax ruling. Em. T. Employment tax ruling. F.A.A.A. Federal Alcohol Administration Act. F.I.C.A. Federal Insurance Contributions Act. F.R. Federal Register. FUTA Federal Unemployment Tax Act. G.C.M. Chief Counsel's memorandum (formerly General Counsel's memorandum). I.R.B. Internal Revenue Bulletin. places or businesses, according to context. M.T. Miscellaneous tax ruling. Mim. Published mimeograph. 0.D. Office Decision. P.L. Public Law. PS Pension, profit-sharing, stock bonus or annuity plan ruling. x and y are used to represent certain numbers and when used with the word "dollars" represent sums of money. |