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Samples in periodicals archive:
The issuance of the tax -exempt bonds for both projects is contingent on the receipt from the Internal Revenue Service of a favorable private letter ruling.
Yet, in Private Letter Ruling 200121031, the IRS addressed damages for a disease, finding a recovery against an asbestos manufacturer to be excludable, even though there was no physical contact with the plaintiff.
The site's databases, which are updated frequently, include tax case law from 1990 to present, revenue rulings and revenue procedures from 1954 to present, private letter rulings from 1979 to present, and numerous other IRS administrative materials with varying date coverage.
WPS Resources believes that it is justified in relying on IRS private letter rulings for its synthetic fuel facility, that the test results that it presented to the IRS in connection with its private letter rulings are scientifically valid, and that the facility has been operated in compliance with the private letter rulings and Section 29 of the Internal Revenue Code.
For example, the IRS issued a number of private letter rulings to taxpayers that sanctioned a hospital's sale of part of its operations revenue stream to a joint venture between the hospital and medical staff physicians.
Companies Also Announce Name of New Company Will Be PharMerica Corporation, Headquarters to be in Louisville, KY, and Receipt of IRS Private Letter Ruling
A recently released IRS Private Letter Ruling offers some assurance to those considering this strategy.
Thus, in appropriate cases, tax liability insurance can provide tax certainty when a private letter ruling is not available.