In contrast to Revenue Ruling
58-301, Revenue Ruling
75-44, 1975-1 C.
Since 2001, the debate over revenue rulings
has shifted due to a Supreme Court case involving a U.
The proposed revenue ruling
emphasizes the need for written documentation regarding physician recruitment activities.
The second ruling, Revenue Ruling
2004-110, concerns payments made in connection with the cancellation of an employment contract.
Treasury Department has changed its policy in Revenue Ruling
2002-19 and will now allow deductions for this malady in certain instances.
In revenue ruling
2004-110, the IRS effectively reversed its position on cancellation payments in the context of an employer-employee relationship, concluding that amounts paid to an employee as consideration for the cancellation of an employment contract and relinquishment of contract rights were wages subject to Social Security, Medicare, and federal unemployment and income tax withholding.
95-22 clarifies that proceeds received for the loss of a home and scheduled personal property can be reinvested in the home and/or contents, and restates that money received for contents is exempt from income, regardless of how the money is used.
Many of the issues raised in the revenue rulings
have been resolved in the courts and have become case law precedent.
332 liquidation of H&C, Dover concluded that the IRS's position violated the principle of Rauenhorst, 119 TC 157 (2002), that "taxpayers should he entitled to rely on revenue rulings
in structuring their transactions, and they should not be faced with the daunting prospect of the Commissioner's disavowing his rulings in subsequent litigation.
If other courts interpret Mead in the same way they would have to follow all IRS revenue rulings
as long as they are consistent with the statute and reasonable.
1) Overall, the number of precedential published guidance (regulations, revenue rulings
, revenue procedures, and notices) noticeably decreased between 1980 and 2000.
Tax Links is especially notable for its links to online databases of IRS revenue procedures (1995 to present) and IRS revenue rulings
(1970 to present).