|
|
|
|
IRS Technical Memoranda
FILE-NAME: TM
COVERAGE: From July 1967 through June 2002
FREQUENCY: No longer published
UPDATE-SCHEDULE: No longer updated
CONTENT-SUMMARY:
IRS Technical Memoranda (TM file) are documents issued by the Internal Revenue Service which examine final regulations.
These documents are no longer published by the IRS.
PUBLISHER:
Internal Revenue Service
SEGMENT-DESCRIP: | CITE | The CITE segment contains the LEXIS cite of a document. | | | CITE (2002 TM LEXIS 2) | | | | | DATE | The DATE segment contains the date of case. | | | DATE=6/21/2002 | | | | | REFERENCE | The REFERENCE segment contains the internal IRS number assigned to the document. | | | REFERENCE (POSTF-118402-02) | | | | | TEXT | The TEXT segment contains the full-text of a document. | | | TEXT (maritime security fleet) | | | |
DOC-DESCRIPTION:
Each memorandum represents a document.
DISPLAY-SEQUENCE:
Documents display in reverse chronological order.
USE-TIPS:
To find a Technical Memoranda which examines proposed rulemaking on Minimum
Coverage Requirement under section 410(b), ENTER:
rule! w/5 minimum coverage requirements
HIER-LOC:
Area of Law - By Topic/Accounting/Access Directories/Tax Center/Federal/Primary/IRS
Area of Law - By Topic/Accounting/Find Statutes, Regulations & Administrative Materials/By Subtopic/Taxation/Find Federal Administrative Materials/Agency Decisions
Area of Law - By Topic/Administrative Law/Find Specific Agency Decisions & Materials/Tax - Federal
Area of Law - By Topic/Federal Practice/Find Statutes, Regulations, Administrative Materials & Court Rules/Adminstrative Agency Materials/Taxation/Agency Decisions
Area of Law - By Topic/Financial Crisis Litigation/Find Statutes, Regulations, Administrative Materials & Court Rules/Administrative Agency Materials/Taxation/Find Federal Administrative Materials/Agency Decisions
Area of Law - By Topic/Taxation/Find Federal Administrative Materials/Agency Decisions
Federal Legal - U.S./Find Statutes, Regulations, Administrative Materials & Court Rules/Administrative Agency Materials/Taxation/Agency Decisions
SAMPLE-DOC:
This document is not to be relied upon or otherwise cited as precedent by taxpayers.
Technical Memoranda
CONTRIBUTIONS TO THE CAPITAL OF A CORPORATION
2002 TM LEXIS 2
June 21, 2002
[*1]
REFERENCE: POSTF-118402-02/CC:PSI:B5
TEXT:
MEMORANDUM FOR ASSOCIATE INDUSTRY COUNSEL TO THE SHIPPING TECHNICAL ADVISOR CC:LM:HMT:PHI
FROM: ASSOCIATE CHIEF COUNSEL (PASSTHROUGHS AND SPECIAL INDUSTRIES) CC:PSI
This Chief Counsel Advice responds to your memorandum dated March 26, 2002. In accordance with I.R.C. § 6110(k)(3), this Chief Counsel Advice should not be cited as precedent.
LEGEND
Taxpayer:
Subsidiary:
Year 1:
Year 2:
ISSUE
Whether Taxpayer may exclude from income under § 118(a) cash payments it received from the Department of Transportation (DOT) under the Maritime Security Fleet Program.
CONCLUSION
Taxpayer may not exclude from income under § 118(a) cash payments it received from the DOT under the Maritime Security Fleet Program.
FACTS
Taxpayer through Subsidiary has contracted with the DOT under the Maritime Security Fleet Program. The operating agreements conform to the requirements of the Maritime Security Fleet Program statute described below.
Pursuant to the operating agreements, Taxpayer received cash payments in Year 1 and Year 2. Taxpayer did not include these cash payments on its income tax returns for Year 1 and Year 2. Taxpayer contends that the payments are excluded from income under § 118(a).
LAW [*2] AND ANALYSIS
Maritime Security Fleet Program
46 U.S.C. 1187(a) provides that the Secretary of Transportation shall establish a fleet of active, militarily useful, privately-owned vessels to meet national defense and other security requirements and maintain a United States presence in international commercial shipping. The Fleet must consist of privately owned, United States-flag vessels for which there are in effect operating agreements and shall be known as the Maritime Security Fleet.
[REMAINDER OF TEXT OMITTTED IN ORDER TO SHORTEN EXAMPLE]
|
|
