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1920 No. 3 C.B. 1 (1920)

handle is hein.usfed/ircb0003 and id is 1 raw text is: Treasury Department : : Bureau of Internal Revenue Cumulative Bulletin No. 3 JULY-DECEMBER, 1920 INCOME TAX RULINGS Nos. 1034-1368, Inclusive THE INCOME TAX RULINGS constitute a service of information from which taxpayers and their counsel may obtain the best available indication of the trend and tendency of official opinion in the administration of the income and profits tax proisions of the Revenue Acts. The rulings have none of the force or effect of Treasury Decisions and do not commit the Department to any interpretation of law which has not been formally approved and promulgated by the Secre. tory of the Treasury. Each ruling embodies the administrative application of the law and Treasury Decisions to the entire state of facts upon which a particular case arises. It is especially to be noted that the same result will not necessarily be reached in another case unless all the material facts are identical with those of the reported case. As it is not always feasible to publish a com- plete statement of the facts underlying each ruling, there can be no assurance that any now Case is identical with the reported case. As bearing out this distinction, it may be observed that the ralings published from time to time may appear to reverse rulings previously publishad. Officers of the Bureau of Internal Revenue are especially cautioned against reaching a con- clusion in any case merely on the basis of similarity to a published Income Tax Ruling, and should base their judgment on the application of all pertinent provisions of the law and Treasury Dec- ams to all of the facts in each case. The Income Tax Rulings should be used merely as aids in studying the law and the Treasury Decisions. WASHINGTON GOVERNMENT PRINTING OFFICE 1921

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