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BULLETIN 1954-3

Business expenses:

Deductible, "kickback" payments...

Capital gains and losses:

Alternative tax, computation, credits allowed corporations___

Credits against net income, net long-term capital gain or loss, computa-
tion, alternative tax....

Deductions:

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Paid credit, allowed corporations, alternative tax computation_...
Received credit, allowed corporations, alternative tax computation__
Employment taxes:

Employer:

Estate tax:

Insurance, life:

Forms:

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Partnerships, change in membership....

11

Receivable by beneficiary other than estate, inclusion in gross

estate__

9

12

W-2, Withholding Tax Statement for 1954, reproduction..

Gift tax:

Gift-splitting, allocation of specific exemption to other spouse.
Specific exemption, not allocable to use of other spouse..
Tax Court of the United States, decision. --

Western Hemisphere corporations, allowable credits, computation, alter-

native tax--

Withholding:

Receipts, Form W-2, reproduction.

10

10

4

8

12

(15)

U. S. GOVERNMENT PRINTING OFFICE: 1954

UNITED STATES

GOVERNMENT PRINTING OFFICE

DIVISION OF PUBLIC DOCUMENTS

WASHINGTON 25, D. C.

OFFICIAL BUSINESS

PENALTY FOR PRIVATE USE TO AVOID
PAYMENT OF POSTAGE, $300
(GPO)

The Internal Revenue Bulletin service consists of Bulletins issued weekly and semiannual Cumulative Bulletins.

The Bulletins contain the rulings and decisions which are made public and all Treasury Department decisions (known as Treasury Decisions) pertaining to Internal Revenue matters. The semiannual Cumulative Bulletins contain all rulings and decisions (including Treasury Decisions) published during the previous 6 months.

The complete Bulletin service may be obtained on a subscription basis from the Superin tendent of Documents, Government Printing Office, Washington 25, D. C., for $1.50 per year; foreign $6.00. Single copies of the Bulletin, 10 cents each.

Certain issues of Cumulative Bulletins are out of print and are, therefore, not available. Persons desiring available Cumulative Bulletins which are listed below may obtain them from the Superintendent of Documents at prices as follows:

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1 House, Senate, and conference reports on revenue bills enacted as the act of October 3, 1913, the act of October 22, 1914, and the Revenue Acts of 1916 to 1938, inclusive, and on amendments to such acts.

Printed in one volume.

All inquiries in regard to these publications and subscriptions should be sent to the Superintendent of Documents, Government Printing Office, Washington 25, D. C.

Internal
Revenue

JANUARY 25, 1954 BULLETIN

No. 4

HIGHLIGHTS OF THIS ISSUE:

Proposed T. D. announced reflecting rules and
procedures relating to amortization deduc-
tion for public grain storage facilities... Page 3.
A public grain warehouse may qualify for
special amortization deduction even though
the owner constructs it next to, and uses
loading and other equipment of, a similar
warehouse which it owns..

...

Rev. Rul. 54-33, page 7.

Rev. Rul. 54--34, page 7.

Rev. Rul. 54-39, page 11.

Insurance commissions received pursuant to
agency agreement constitute personal hold-
ing company income of a corporation where
the principal has the right to designate the
person to perform the services . . .
There is no standard form of exemption cer-
tificate for establishing the nontaxable char-
acter of payments made outside the United
States for transportation of persons.
The Revenue Service announces its Federal
employment tax treatment of cost-of-living
allowances paid to United States civilian em-
ployees stationed outside the United States. . Rev. Rul. 54-40, page 9.
Merely being a charitable, scientific, or similar
organization exempt from some Federal
taxes will not automatically provide exemp-
tion from stamp taxes on stock issues or
transfers.

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Rev. Rul. 54-38, page 11.

An agent who prepares a Federal estate tax
return is not prevented from later assisting
the taxpayer in establishing a different value
for items of property shown on that return.. Rev. Rul. 54–36, page 8.
The tax on initiation fees applies to fees paid
by incoming club member rather than retir-
ing members. Rev. Rul. 137 clarified
The certification of a copy of a will required
by the estate tax regulations must be made
by the register of wills or his authorized
representative

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Continued on page 3

Rev. Rul. 54-37, page 10.

Rev. Rul. 54-35, page 8.

Index on page 15.

Finding List on page 16.

TREASURY DEPARTMENT

• INTERNAL REVENUE SERVICE

UNIVERSITY OF MICHIGAN

GENERAL LIBRARY

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,
Washington 25, D. C Price 10 cents (single copy). Subscription price:
$4.50 a year; $1.50 additional for foreign mailing.

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ANNOUNCEMENT RELATING TO

PROPOSED REGULATIONS PUBLISHED WITH NOTICE OF PROPOSED RULEMAKING

Under the Administrative Procedure Act, changes in regulations are (with certain exceptions described in such act) published in the Federal Register in tentative or proposed form to provide interested parties with an opportunity to file their objections or suggestions for consideration prior to final adoption of such regulations. The Internal Revenue Service will announce in the Internal Revenue Bulletin the issuance of tentative or proposed regulations relating to internal revenue matters which have been published in the Federal Register with notice of proposed rulemaking. These announcements will appear in the Bulletin during the period which has been prescribed for the submission and consideration of any views, arguments, or suggestions pertaining to the proposed regulations so published. Statements of such views, arguments, or suggestions should be submitted in writing in duplicate to the Commissioner of Internal Revenue, Washington 25, D. C.

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