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Also included in this part are Bank Secrecy Act Administrative Rulings.
Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases.All published rulings apply retroactively unless otherwise indicated.Procedures relating solely to matters of internal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published.In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same.The Bulletin is divided into four parts as follows: To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts.Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling.
In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements.
At the time of this distribution, the fair market value of the P indebtedness is $9,250,000.
During Year 3, S makes no other distributions to P.
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.
The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest.