Get Revenue Ruling 1999-9 - LIFO

A revenue ruling is an official interpretation by the IRS of the Internal Revenue Code, related statutes, tax treaties and regulations. It is the conclusion of the IRS on how the law is applied to a specific set of facts.

Revenue Ruling 2009-9 clarifies several issues regarding the treatment and effect of theft losses resulting from fraudulent investment schemes. Revenue Procedure 2009-20 contains a safe harbor through which electing taxpayers can claim their theft loss resulting from the Madoff scheme in 2008.

Rul 99-23 holds that expenditures incurred in the course of a general search for, or investigation of, an active trade or business in order to determine whether to enter a new business and which new business to enter (other than costs incurred to acquire capital assets that are used in the search or investigation) ...

99-40. This revenue ruling states that when a taxpayer elects to apply an overpayment to a succeeding year's estimated taxes, the overpayment will be applied to unpaid estimated tax installments due on or after the date of the overpayment, in the order required to avoid a penalty for the failure to pay estimated tax.

The ruling states that for purposes of determining the tax consequences to the purchaser, (i) the partnership is deemed to make a liquidating distribution of all of its assets to its partners and (ii) immediately thereafter, the purchaser is viewed as purchasing the seller's interest in the partnership's assets.

IRS Revenue Ruling 99-5 lays out guidance for two situations in which an LLC targeted for acquisition is treated as a disregarded entity – and separate from the organization that owns it – for federal income tax purposes. Let's explore how each scenario plays out.

The LLC gets to keep operating normally after switching to single-member ownership, but the tax payment requirements change quite a bit. From the perspective of the IRS, changing from an LLC with more than one member to a single-member LLC is considered the end of the partnership tax status.

84-111 describes the differences in the basis and holding periods of the various assets received by the corporation and the basis and holding periods of the stock received by the former partners provided the steps described are actually undertaken and the underlying assumptions and purposes for the conclusions in the ...