The ruling specifically distinguishes Revenue Ruling
77-17, which held that losses sustained in the open market resulting from fraudulent activity of a corporation's officers or directors are capital in nature.
* TD 9478 and REG-131028-09, Revenue Rulings
2010-4 and 2010-5
In March, the IRS issued Announcement 95-25, which contained proposed revenue ruling
regarding the impact of certain physician recruitment incentives on the tax-exempt status of hospitals that recruited physicians for their nonemployee medical staffs or to provide services on behalf of the hospitals.
The IRS issued four notices and three revenue rulings
addressing technical issues of automatic contributions to qualified employer-sponsored retirement plans and clarifying that contributions may be made from payments of the value of paid vacation or other leave.
Although Correll elevates longstanding rulings that have Congressional approval to some type of legal status on par with statutes, the average revenue ruling
does not fall into that category.
94-38 identifies a very specific fact situation: An accrual basis taxpayer purchased uncontaminated land.
Also, as mentioned in note 2 and the accompanying text, the IRS will have a difficult time disavowing its own published revenue ruling
, as supplemented by its informal reaffirmation of its conclusion.
2002-9 is an important concession from the IRS.
The frequency showed "a degree of recurrence, continuity and availability" (Revenue Ruling
The second personal health account ruling, IRS Revenue Ruling
2005-24, applies to employers who contribute funds to employee health reimbursement arrangements.
Now, Revenue Ruling
2005-4 extends the scope of the existing regulation to include additional taxes voluntarily reported by taxpayers on amended returns or in IRS correspondence.
Treasury Department has changed its policy in Revenue Ruling
2002-19 and will now allow deductions for this malady in certain instances.