held that Newco could amortize the cost of the goodwill acquired in the purchase of assets from X.
1) the ruling
involves a controlling question of law or policy as to which substantial grounds exist for a difference of opinion;
Finally, the proposed revisions to ethics ruling
For example, the ruling
noted that schools can still use religious materials in an objective, academic manner, students are free to wear clothing or jewelry with religious messages or symbols and students can distribute religious materials to classmates during non-instructional time.
The Service granted these entities relief and allowed S status from inception, as long as both forms were filed within 60 days of the ruling
35, had held such costs to be ordinary and necessary business expenditures, the IRS has now taken the position that the earlier ruling
was intended to address only section 263(a) and was not intended to suggest that manufacturers need not consider the possible applicability of section 263A.
It then decided the ruling
should not apply to its 1989 tax return and filed a refund claim.
For example, the Supreme Court anointed a ruling
involving the so-called "overnight rule" under the statute permitting business travelers to deduct meal and lodging expenses.
While Walker's residence was not established as his principal place of business under the home-office deduction standards, it was established as his regular place of business under the language of revenue ruling
However, Form 2553 was not filed prior to the ruling
The organization urged the Supreme Court not to treat a Customs Service or IRS ruling
as a policy decision that courts must accept if it is minimally rational.
A letter ruling
generally is binding on an IRS district office for purposes of determining a taxpayer's liability.