Internal Revenue Bulletin: 2005-24 |
June 13, 2005 |
Table of Contents
- Highlights of This Issue
- Preface
- Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
- Part III. Administrative, Procedural, and Miscellaneous
- Notice 2005-43
- Purpose
- Effective Date
- Request for Comments
- Drafting Information
- PROPOSED REVENUE PROCEDURE
- SECTION 1. PURPOSE
- SECTION 2. LAW AND DISCUSSION
- SECTION 3. SCOPE
- SECTION 4. SAFE HARBOR
- SECTION 5. APPLICATION OF SAFE HARBOR TO SERVICE PROVIDER AND SERVICE RECIPIENT
- SECTION 6. EXAMPLES
- SECTION 7. EFFECT ON OTHER DOCUMENTS
- Notice 2005-45
- A. BACKGROUND
- B. APPLICATION
- (1) In general
- (2) Use of aircraft for entertainment
- (3) Specified individuals
- (4) Expenses of aircraft subject to disallowance
- (5) Method of allocating expenses to flights
- (6) Special rule for “deadhead” flights
- (7) Allocation of expenses on trips of a specified individual involving both business and entertainment
- (8) Non-commercial flight valuation consistency rule
- (9) Interaction with § 162(m)
- (10) Costs treated as compensation
- C. REQUEST FOR COMMENTS
- D. EFFECTIVE DATE
- E. TRANSITION RULE FOR REPORTING DISALLOWED EXPENSES
- DRAFTING INFORMATION
- Rev. Proc. 2005-33
- Rev. Proc. 2005-34
- SECTION 1. PURPOSE
- SECTION 2. BACKGROUND
- SECTION 3. SCOPE
- SECTION 4. PROCEDURE IN AREA COLLECTION DIVISIONS
- SECTION 5. PROCEDURE FOR APPEALING A PROPOSED ASSESSMENT AND REQUESTING AN APPEALS CONFERENCE
- SECTION 6. REPRESENTATION AT CONFERENCE
- SECTION 7. EXTENSION OF THE PERIOD OF LIMITATIONS FOR ASSESSMENT
- SECTION 8. PROCEDURE IN AREA DIRECTOR’S OFFICE FOR DISPOSING OF CLAIMS
- SECTION 9. EFFECT ON OTHER DOCUMENTS
- SECTION 10. EFFECTIVE DATE
- DRAFTING INFORMATION
- Notice 2005-43
- Part IV. Items of General Interest
- REG-100420-03
- REG-105346-03
- REG-127740-04
- Announcement 2005-42
- Introduction
- Background
- Pre-Filing Agreement Program Accomplishments
- Statistical Overview of PFA Program — Calendar Year 2004
- Description of Applications Received in Calendar Year 2004
- Reasons Why Applications Received in Calendar Year 2004 Were Not Accepted
- PFA Program Summary (2004 and Prior Calendar Years)
- Taxpayer Withdrawals (4)
- IRS Withdrawal (8)
- Mutual Withdrawal (1)
- PFAs Executed (27)
- PFAs Executed in 2004
- Deductibility and Fair Market Value of Donated Property (6)
- Amount of Qualified Research and Experimental Credit (6)
- Fair Market Value of Stock Exchanged (1)
- Cost Segregation for Asset Class and Recovery Periods (1)
- Treatment of License Fee Income (1)
- Deductibility of Fees to Purchase Tax Exempt Securities (1)
- Gain or Loss on Sale of Stock (1)
- Worthless Securities and Bad Debts (6)
- Fuel Credit (1)
- Ordinary Versus Capital Loss on Property Sale (1)
- Writedown of Inventory (1)
- Deductibility of Fines and Penalties (1)
- Closing Agreements
- PFA Program Utilization
- Processing Statistics
- Pre-Filing Agreement Program Summary
- Definition of Terms and Abbreviations
- Numerical Finding List
- Effect of Current Actions on Previously Published Items
- How to get the Internal Revenue Bulletin
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