(Rev. Proc. 67–6, 1967–1 C.B. 576)

The following is a complete list of rulings that have been declared obsolete during the period July-December 1978 in accordance with the program announced in Revenue Procedure 67-6 for the review of rulings published prior to 1953. (See 1967-2 C.B. X, 1968-2 C.B. XIII, 1969-2 C.B. VII, 1970-2 C.B. XI, 1971-2 C.B. XII, 1972-2 C.B. XII, 1973-2 C.B. X, 19742 C.B. IX, 1975-2 C.B. 506, 1976-2 C.B. 449, 450, 1977-2 C.B. 485, 486, and 1978-1 C.B. IX for a listing of rul

ings declared obsolete in 1967, 1968, 1969, 1970, 1971, 1972, 1973, 1974, 1975, 1976, 1977, and 1978, respectively.) The rulings, are arranged by

series in numerical order. Citations are to Cumulative Bulletins.

All rulings published after 1921 are contained in the Internal Revenue Bulletin rather than in separate Income Tax and Sales Tax Bulletins. Cumulative Bulletin I-1 covers the first six months of 1922, and each subsequent semiannual Cumulative Bulletin through the last six months of 1936 is similarly identified by a Roman numeral prefix and an Arabic numeral which denoted the first or the second

Published in the Internal Revenue Bulletin

from January 1, 1978 through December 31, 1978

It is the policy of the Internal Revenue Service to announce in the Internal Revenue Bulletin at the earliest practicable date the determination of the Commissioner to acquiesce or not acquiesce in a decision of the Tax Court which disallows a deficiency in tax determined by the Commissioner to be due.

Notice that the Commissioner has acquiesced or nonacquiesced in a decision of the Tax Court relates only to the issue or issues decided adversely to the Government.

Actions of acquiescences in adverse decisions shall be relied on by Revenue officers and others concerned as con

clusions of the Service only to the application of the law to the facts in the particular case. Caution should be exercised in extending the application of the decision to a similar case unless the facts and circumstances are substantially the same, and consideration should be given to the effect of new legislation, regulations, and rulings as well as subsequent court decisions and actions thereon.

Acquiescence in a decision means acceptance by the Service of the conclusion reached, and does not necessarily mean acceptance and approval of any or all of the reasons assigned by the Court for its conclusions.

No announcements are made in the Bulletin with respect to memorandum opinions of the Tax Court.

The announcements published in the weekly Internal Revenue Bulletins are consolidated semiannually and annually. The semiannual consolidation appears in the first Bulletin for July and in the Cumulative Bulletin for the

first half of the year and the annual consolidation appears in the first Bulletin for the following January and in the Cumulative Bulletin for the last half of the year.

The Commissioner ACQUIESCES in the following decisions:

Report