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1924 III-1 C.B. [i] (1924)

handle is hein.usfed/ircb0010 and id is 1 raw text is: SPECIAL ATTENTION is &ectled to the cautionary notice on this page that publisdd rulings of the Bureau do not have the force and efct of Treat, ury Decisions and that they are applicable only to the facts presented in the publishad case. Treasury Department Bureau of Internal Revenue Internal Revenue Bulletin Cumulative Bulletin III-1 JANUARY-JUNE, 1924 IN THIS ISSUE P4V Rulings Nos. 1277-1641- Income Tax ............ 1-448 Sales Tax ............. 449-469 Estate Tax .. .. ............ 470-488 Capital Stock Tax :...... ........... 489-499 Misellaneous Ta,...........500-506 Miscellaneous .... ........... ..507-537 The rulings reported In the Internal Revenue Bulletin are for the information .of taxpayers and their counsel as showing the trend of offieal 'opinion in thi adminis- tration of the Bureau of Internal Revenue; the rulings other than Treasury Decisions have none of the force or effect of Treasury Decisions and do not commit the De- partment to any interpretation of the law which has not been formally approved and promulgated by the Secretary of the Treasury. Each: ruling embodies the admin- istrative application of the law and Treasury Decisions to the entire state of facts upon which a particular case rests. It is especially to be noted that the same re- sult 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 publishe a complete statement of 'the facts underlying each ruling, there can be no assurance that any new case is idintical with the reported case. As bearing out this distinc- tion, it may be observed that the rulings published from time to time may appear to reverse rulings previously published. Officers of the Bureau of Internal Revenue are especially cautioned against reach- ing a conclusion In any case merely on the basis of similarity to a published ruling, and should base their judgment on the application of al pertinent provisions of the law-and Treasury Decisions to all .the facts in each case. These rulings should be used as aids in studying the law and its formal construction as made in the regula. tions and Treasury Decisions previously issued. . In addition to publishing all Internal Revenue Treasury Decisions and all formal Solictor's opinions, it Is the policy of the Bureau of Internal Reyanue to publish all rulings and decisions, including memorandum opinions of the Solicitor of Internal Revenue and recommendations of the Committee on Appeals and Review, which, be- cause they announce a ruling or'dectelon upon a novel question or upon a question In regard to which there exists no previously published ruling or decision, or for other reasons, are of such importance as to be of general interest. It is also the policy of the Bureau to publish all rulings or decisions which revoke, modify, amend, or affect in any manner whatever any published'rullng or decision. In many instances memo- randum opinions of the Solicitor of Internal Revenue and recommendations of the Committee on Appeals and Review are not of general interest because they announee no new ruling or no new construction of the revenue laws but simply apply rulings already made public to certain situations of fact which are without special signifi- cance. It Is not the policy of the Bureau to publish such memorandum opinions and recommendations. Therefore, the numbers assigned to the published memorandmu opinions of the Solicitor of Internal Revenue and to the published recommendations of the Committee on Appeals and Review are not consecutive. No unpublished rul- Ing or decision will be cited or relied upon by any oMcer or employee of the Bureau of Internal Revenue as a precedent in the disposition of other cases. Unless other- wise specifcally indicated, all published rulings and decisions have received the con. sideration and approval of the Solicitor of Internal Revenue. WASHINGTON : : GOVERNMENT PRINTING OFFICE s a a : a . 1924.

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