Exempt corporations and associations, farmers' cooperatives, purchases for persons who are neither members nor producers... Foreign tax credit: Brazilian tax on corporations.... Taxes paid on income exempt from United States tax.. Gain or loss: Recognition, exchange of new second preferred stock for common stock on reorganization_.... Gift tax: Transfers, leaseback of property, rental payments by grantcr to trustee.. Gross income: Page 13 16 17 14 5 Exclusions, damages under the New Jersey "Death by Wrongful Act” statute received by decedent's estate or by dependents---- 22 Income: From sources within possessions of United States, community income of spouses Partnership: 18 Death of partner, effect on partnership interests and requirements for filing returns.. 18 Return, change in membership during year.. 18 Refunds: (See Claims for refund or abatement.) Personal service corporations, information returns, utilization of Schedule Rent paid, leaseback of property by grantor of trust. Reorganizations, exchange of new second preferred stock for common stock, recognition of gain.... Returns: Information, utilization of Schedule PS (Form 1120) 1951. Tax Court of the United States, decisions____ Taxes: Foreign countries. (See Foreign tax credit.) Trusts: Estates and trusts, leaseback of property by grantor... 21 5 14 21 4 5 U. S. GOVERNMENT PRINTING OFFICE: 1954 The Changes in partnership membership or interests will be given Federal employment tax treatment similar to that adopted for income tax. Revenue Service will not require application of Rev. Rul. 144 to changes in partnership interests which occurred prior to January 1, 1954 . . . Kickback payments made to employees or purchasing agents of customers are not deductible as business expenses if made in violation of Federal Trade Commission Act or Packers and Stockyards Act.... The Revenue Service explains computation of alternative tax on Form 1120 for 1950, 1951 and 1952 and will require redetermination of tax of Western Hemisphere corporations where section Rev. Rul. 54–31, page 11. Rev. Rul. 54–27, page 5. 26 credits have not been properly computed ... Rev. Rul. 54–28, page 8. Decedent's estate does not include life insurance proceeds transferred to former wife as property settlement incorporated in a divorce decree under Alabama law. Rev. Rul. 54-29, page 9. Rev. Rul. 54-30, page 10. Rev. Rul. 54-32, page 12. Pa. 1, page 14. Par. 2, page 14. Par. 3, page 14. Index on page 15. TREASURY DEPARTMENT INTERNAL REVENUE SERVICE UNIVERSITY OF MICHIGAN INTRODUCTION The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for the announcement of official rulings of the Internal Revenue Service, and for the publication of Treasury Decisions, Executive Orders, legislation, and court decisions pertaining to Internal Revenue matters. It is the policy of the Service to publish in the Bulletin all substantive and procedural rulings of importance or general interest, the publication of which is considered necessary to promote a uniform application of the laws administered by the Service. It is also the policy to publish all rulings which revoke, modify, amend, or affect any published ruling. Rulings relating solely to matters of internal management are not published. The rulings are prepared in the various divisions of the National Office, including the Office of the Chief Counsel for the Internal Revenue Service. All published rulings have received the consideration and approval of the Chief Counsel. Revenue Rulings reported in the Bulletin do not have the force and effect of Treasury Department Regulations (including Treasury Decisions), but are published to provide precedents to be used in the disposition of other cases, and may be cited and relied upon for this purpose. However, since each published ruling represents the conclusion of the Service as to the application of the law to the entire state of facts involved, Revenue officers and others concerned are cautioned against reaching the same conclusion in other cases, unless the facts and circumstances are substantially the same. In applying rulings published in the Bulletin, personnel of the Service will, of course, consider the effect of subsequent legislation, regulations, court decisions, and rulings. Each ruling is designated as a "Revenue Ruling" and should be cited by reference to the year of issuance and the Bulletin and page where reported. Thus, Revenue Ruling No. 3, which is reported on page 8 of the first Bulletin for 1954, should be cited as "Rev. Rul. 54–3, I. R. B. 1954–1, 8,” until it appears in the Cumulative Bulletin, when it should be cited as "Rev. Rul. 54-3, C. B. 1954-1,-." Rulings are keyed to the applicable sections of the Internal Revenue Code and regulations. The Bulletin is published weekly, and the contents thereof are consolidated at least semiannually into a permanent Cumulative Bulletin. Persons so desiring may subscribe to the Bulletin through the Superintendent of Documents, as indicated below. For sale by the Superintendent of Documents, U. S. Government Printing Office, (2) A Cumulative Finding List for all Revenue Rulings, Treasury Decisions, etc., published in Internal Revenue Bulletins 1933-14 to 1953-26 will be found in Internal Revenue Bulletin 1954-1, dated January 4, 1954 (3) ANNOUNCEMENT RELATING TO DECISIONS OF THE TAX COURT OF THE UNITED STATES It is the policy of the Internal Revenue Service to announce in the Internal Revenue Bulletin at the earliest practicable date the determination of the Commissioner to acquiesce or not to acquiesce in a decision of the Tax Court of the United States which disallows a deficiency in tax determined by the Commissioner to be due. Notice that the Commissioner has acquiesced or nonacquiesced in a decision of the Tax Court relates only to the issue or issues decided adversely to the Government. Decision so acquiesced in should be relied upon by officers and employees of the Internal Revenue Service as precedents in the disposition of other cases. (No announcements are made in the Bulletin with respect to memorandum opinions of the Tax Court.) The Commissioner does NOT acquiesce in the following decisions: |