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Posted by / 06-May-2019 23:31

Fi liquidating trust

S, a domestic corporation, has only one class of stock outstanding, all of which is owned by P.

On January 1, Year 2, S purchases all of the P indebtedness from A, an individual not related to S under § 1.108-2(d)(2), for cash in the amount of ,500,000.

Bulletin contents are compiled semiannually into Cumulative Bulletins, which are sold on a single-copy basis.

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin.

Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents.

Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases.

This document establishes an optional procedure for payors who make payments in the course of their trade or business through payment cards to determine whether the payments are reportable under sections 60A of the Code and the regulations thereunder.

This procedure classifies businesses by Merchant Category Codes (MCCs), or other similar codes, according to whether they predominantly furnish services or predominantly provide goods.

The last Bulletin for each month includes a cumulative index for the matters published during the preceding months. Taxpayers also may continue to follow the disclosure procedures provided in section 1.6011-4 for disclosing transactions described in section 1.6011-4(b)(6). This procedure provides a simplified alternate method for certain taxpayers to obtain an extension of time under section 301.9100-3 of the regulations to make an allocation of the generation-skipping transfer exemption in accordance with section 2642(b)(1) of the Code. Final regulations under section 3406 of the Code provide guidance on the information reporting and backup withholding requirements for payment card transactions made through a Qualified Payment Card Agent (QPCA). This procedure provides alternative disclosure procedures that are deemed to satisfy a taxpayer’s disclosure obligations under section 1.6011-4 of the regulations for transactions with a significant book-tax difference under section 1.6011-4(b)(6). The regulations also provide guidance for making the election to treat a trust as a GST trust.On that date, the adjusted issue price of the P indebtedness is ,000,000.On January 1, Year 3, S distributes all of the P indebtedness it holds to P.

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Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling.