the INTRODUCTION The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for the announcement of official rulings and procedures of the Internal Revenue Service, and for the publication of Treasury Decisions, Executive Orders, tax conventions, legislation, and court decisions pertaining to internal revenue matters. Other items considered to be of general interest are also published in the Bulletin, such as announcements relating to proposed regulations published with notice of proposed rulemaking, announcements relating to decisions of The Tax Court of the United States, announcements of the disbarment and suspension of attorneys and agents from practice before the Treasury Department, supplements to the Cumulative List of Organizations contributions to which are deductible under section 170 of the Internal Revenue Code of 1954, Delegation Orders, etc. It is the policy of the Service to publish in the Bulletin all substantive and procedural rulings of importance or of general interest, the publication of which is considered necessary to promote a uniform application of the laws administered by the Service. It is also the policy to publish all rulings and statements of procedures which supersede, revoke, modify, or amend any published ruling or procedure. Except where otherwise indicated, published rulings and procedures apply retroactively. Rulings and statements of procedures relating solely to matters of internal management are not published. However statements of internal practices and procedures affecting rights or duties of taxpayers, or industry regulation, which appear in internal management documents, are published. Revenue Rulings and Revenue Procedures are based upon rulings and internal management documents prepared in the various divisions of the National Office, including the Office of the Chief Counsel for the Internal Revenue Service. In the preparation of these, caution is exercised to conceal the identity of the taxpayer, as well as any confidential personal and business information. Revenue Rulings and Revenue Procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations (including Treasury Decisions), but are published to provide precedents to be used in the disposition of other cases and may be cited and relied upon for that purpose. No unpublished ruling or decision will be cited or relied upon by any officer or employee of the Internal Revenue Service as a precedent in the disposition of other cases. Since each published ruling represents the conclusion of the Service as to the application of the law to the entire state of facts involved, Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same. In applying rulings and procedures pub ABBREVIATIONS The following abbreviations in current use and formerly used will appear in material published in the Bulletin. A, B, C, etc. The names of individuals. A.R.R.-Committee on Appeals and Review recommendation. C.F.R.-Code of Federal Regulations. Del. Order-Delegation Order. E.T.-Estate and gift tax ruling. Em. T.-Employment tax ruling. F.A.A.A.-Federal Alcohol Administration Act. F.R.-Federal Register. G.C.M.-Chief Counsel's memorandum (formerly General Coun sel's memorandum). I.R.B. Internal Revenue Bulletin. IR-Mim.-Published IR-Mimeograph. M, N, X, Y, Z, etc.-The names of corporations, places or businesses, according to context. M.T.-Miscellaneous tax ruling. P.L.-Public Law. P.S.-Pension, profit-sharing, stock bonus or annuity plan ruling. Rev. Proc.-Revenue Procedure. Rev. Rul.-Revenue Ruling. R.S.-Revised Statute. S.M.-Solicitor's Memorandum. Sol. Op.-Solicitor's Opinion. S.P.R.-Statement of Procedural Rules. S.R.-Solicitor's Recommendation. S.S.T.-Social Security Tax. S.T.-Sales tax ruling. Stat. Statutes at Large. T.C.-The Tax Court of the United States. T.D.-Treasury Decision. TIR-Technical Information Release. U.S.C.-United States Code. x and y used to represent certain numbers and when used with the word "dollars" represents sums of money. VI INTRODUCTION The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for the announcement of official rulings and procedures of the Internal Revenue Service, and for the publication of Treasury Decisions, Executive Orders, tax conventions, legislation, and court decisions pertaining to internal revenue matters. Other items considered to be of general interest are also published in the Bulletin, such as announcements relating to proposed regulations published with notice of proposed rulemaking, announcements relating to decisions of The Tax Court of the United States, announcements of the disbarment and suspension of attorneys and agents from practice before the Treasury Department, supplements to the Cumulative List of Organizations contributions to which are deductible under section 170 of the Internal Revenue Code of 1954, Delegation Orders, etc. It is the policy of the Service to publish in the Bulletin all substantive and procedural rulings of importance or of general interest, the publication of which is considered necessary to promote a uniform application of the laws administered by the Service. It is also the policy to publish all rulings and statements of procedures which supersede, revoke, modify, or amend any published ruling or proce dure. Except where otherwise indicated, published rulings and procedures apply retroactively. Rulings and statements of procedures relating solely to matters of internal management are not published. However statements of internal practices and procedures affecting rights or duties of taxpayers, or industry regulation, which appear in internal management documents, are published. Revenue Rulings and Revenue Procedures are based upon rulings and internal management documents prepared in the various divisions of the National Office, including the Office of the Chief Counsel for the Internal Revenue Service. In the preparation of these, caution is exercised to conceal the identity of the taxpayer, as well as any confidential personal and business information. Revenue Rulings and Revenue Procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations (including Treasury Decisions), but are published to provide precedents to be used in the disposition of other cases and may be cited and relied upon for that purpose. No unpublished ruling or decision will be cited or relied upon by any officer or employee of the Internal Revenue Service as a precedent in the disposition of other cases. Since each published ruling represents the conclusion of the Service as to the application of the law to the entire state of facts involved, Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same. In applying rulings and procedures pub lished in the Bulletin, personnel of the Service and others concerned must consider the effect of subsequent legislation, regulations, court decisions, rulings, and procedures. Each published ruling is designated as a "Revenue Ruling," and each published procedure is designated as a "Revenue Procedure." These should be cited by reference to the year of issuance and the Bulletin and page where reported. Thus, Revenue Ruling No. 20 for 1962 should be cited as "Rev. Rul. 62-20, C.B. 1962-1, 21." Similarly, Revenue Procedure No. 4 for 1962 should be cited as "Rev. Proc. 62-4, C.B. 1962-1, 425." Revenue Rulings are keyed to the applicable sections of the Internal Revenue Code and Regulations. The regulations, rulings, decisions, procedures, etc., published in the weekly Internal Revenue Bulletins 1962-27 through 1962-53 have been consolidated and are published in Internal Revenue Cumulative Bulletin 1962-2. Internal Revenue Cumulative Bulletin 1962-3 contains the Public Laws pertaining to internal revenue matters enacted during the Second Session of the 87th Congress on or after May 24, 1962, together with their related Committee Reports, and a digest of tax legislation enacted during the Second Session. A topical index to such Public Laws is also included. Cumulative Bulletin 1962-3 is prepared in three parts, as follows: II. Part II contains the Public Laws pertaining to internal III. Part III contains Committee and Conference Reports related to the legislation published in Part II. House, Senate, and Conference Committee Reports printed in the Bulletin do not include the portion entitled "Changes in Existing Law." |