Boone,(20) the court
ruled that a single transaction involving 383 grams of cocaine along with conversations between the purchaser and wholesaler indicating there would be future sales was enough to infer a conspiracy between the buyer and the seller.
In that case, the SBE
ruled that the regulation contradicted the plain meaning of the California statutes corresponding to UDITPA [subsection] 1(g) and 15:
The IRS
ruled that the S election was inadvertently invalid.
The Service
ruled the termination was inadvertent, and the corporation was allowed to retain S status.
The Service
ruled that the invalid elections were inadvertent and allowed the corporation to retain its S status and the trusts to be QSSTs, as long as Form 2553 and a QSST election with the proper signatures were filed.
(27) The IRS
ruled (28) that an S corporation could not retroactively change to the cash method because it would have been earlier than the revenue procedure's effective date.
The IRS favorably
ruled that the amounts placed in the irrevocable trust for the rabbi would not be included in the rabbi's taxable income until actually received by or otherwise made available to him.
The IRS
ruled that the amendment did not violate Sec.
With respect to the computation of CTI for FSC or DISC purposes, however, the IRS has
ruled that the congressional moratorium does not apply.
The Service
ruled that the temporary conversion did not ternfinate the initial S election.
The Federal Circuit
ruled that the elaborate scheme lacked economic substance and created no gain or loss for Federal tax purposes; it remanded the case to decide whether the partnership was a total sham created for the sole purpose of tax avoidance that should be disregarded for Federal tax purposes.
In Letter Ruling 200240049, the Service
ruled that a comprehensive like-kind-exchange (LKE) program providing for various transfers of relinquished vehicles, followed by acquisitions of replacement vehicles through a taxpayer's dealer network using a qualified intermediary (QI), is a deferred exchange that qualifies for Sec.
The IRS
ruled that the (1) partnership would be taxed as an S corporation and (2) transaction did not create a second class of stock.
2000), the Department
ruled that an out-of-state furniture seller was liable for uncollected Virginia use tax on furniture deliveries that a common carrier made into the state, after the seller had voluntarily registered to collect Virginia sales and use tax during a previous audit.
Although the IRS
ruled that the election was ineffective, it was inadvertent under Sec.