Revenue Ruling 76-255 deals with the rare circumstance in which joint filers can switch to separate returns.
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One of my earliest blog posts noted the relief that the IRS granted in Revenue Ruling 2009-9.
Last year in Revenue Ruling 2008-5, the IRS explicitly said this would run afoul of the wash sale rule.
The new IRS ruling, technically a "revenue ruling" that applies to all taxpayers, puts both these fears to rest.
Result: they had no right to file joint returns (Revenue Ruling 76-255).
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Another REIT which might be expected to take advantage of a positive revenue ruling in a big way is Power REIT (NYSE:PW).
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No one was able to tell me anything definite, but there are rumors that a request for an IRS revenue ruling is imminent.
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The fact that NREL issued this report suggests that someone in the government is working to prepare the way for a favorable revenue ruling.
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Of course, even a shareholder who pays himself a substantial salary can enjoy the benefits of reduced payroll taxes by virtue of Revenue Ruling 59-221.
Revenue Ruling 2012-18 clarifies that the IRS believes a tip to be what you and I would leave our server in addition to the bill.
In Revenue Ruling 88-31, however, the IRS concluded that a different kind of CVR used for hedging should be treated for tax purposes as an option.
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But in 1976, it said in a revenue ruling that contributions to a fund to help pay for a congressman's official travel were taxable income to him, not gifts.
On July 6 it released a "revenue ruling" that clears up long standing gift and estate tax issues relating to an estate-planning tool--irrevocable grantor trusts--widely used by wealthy families.
When I wrote the article, I knew there were rumors that a revenue ruling might be requested soon, but not if any taxpayers had yet requested private letter rulings.
This is not a concern with S corporations, as courtesy of Revenue Ruling 59-221, income that flows through to shareholders from an S corporation is not subject to self-employment tax.
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The conservatism of REIT managers has most likely already proven a barrier to some potential solar installations on REIT property, and a positive revenue ruling would have the added advantage of giving a green light for existing REITs to install solar on their property.
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Then the shelter promoter whips out a 1969 Internal Revenue Service ruling declaring that since the value of the annuity isn't known, the gain can't be taxed up front.
Under the old law expatriates could apply to the Internal Revenue Service for a ruling confirming they had left the U.S. for nontax reasons and were therefore exempt from the ten-year levy.
The Department of Revenue Board of Tax Appeals in ruling against the Institute remarked that Go is fundamentally a recreational board game like chess.
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Seeking a private letter ruling from the Internal Revenue Service.
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The biggest open question in my article Solar REITs: A Better Way to Invest in Solar was, when will we have a ruling from the Internal Revenue Service (IRS)?
Then ask your lawyer about a new approach that the Internal Revenue Service blessed in a private letter ruling just issued in January.
As such, they did not feel comfortable supplanting the functions of the Internal Revenue Service or the tax court in rendering a ruling on what they believed to be an unsettled area of the law.
But Trans World International, the Pakistan Cricket Board's broadcasting partner, which provides the ruling body with about 90% of its revenue, recommended Nairobi instead.
But that ruling might not daunt Covad, since the bulk of its revenue comes from business customers.
The ruling "could ripple through the developing world and affect the fundamentals of the pharmaceutical revenue model, " The Indian Express said in an editorial.
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