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1925 IV-1 C.B. [i] (1925)

handle is hein.usfed/ircb0012 and id is 1 raw text is: SPECIAL ATTENTION is directed to the cautionary notice on this page that published rulings of the Bureau do not have the force and effect of Treasury Decisions and that they are applicable only to the facts presented In the published case. Treasury Department Bureau of Internal Revenue Internal Revenue Bulletin Cumulative Bulletin IV-i JANUARY-JUNE, 1925 IN THIS ISSUE Pge Rulings Nos. 1950-2251- Income Tax ... ............ ... 1-293 Sales Tax . ..... ............ . 294-321 Estate Tax ... ............. 322-324 Capital Stock Tax . .......... 325-335 Miscellaneous Tax .......... 336-361 Miscellaneous . . . ...... ......362-413 The rulings reported in the Internal Revenuo Bulletin are for the information of taxpayers and their counsel as showing the trend of official opinion in the adminis. tration of the Bureau of Internal Rovente; 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'interretatlon of the law wich has not boen formally approved and romulgated by the ecrstary of the Treasury. Each ruling embodies the admin- 9trative application of the law and Treasury Decisions to the entire state of facts upon which a particular case rents. It to especially to be noted that the same re- sult will not necessarily be reached in another case unleso all the material facts are identical with those of the reported ease. As It is not always feasible to publish a complete statement of the facts underlying each ruling, there pat% be no assuraneo that any nqw cate is identical with the reported case. As bearinig out this distinc. tion, it may be observed that the rulings published from time to time may appear to rovers rullns ovioutly publiheod. Offears of thw iureau of !nternal Revenue are especially cautioned against reach. Ing a conclusion In any ease merely on the basis of similarity to a pubished ruling, and should base their Judgment on the application of all pertinent provisions of the law and Treasury Decisions to all the fsets in each cage. These rulings should be used as aids In studying the law and Its formal construction as made ti the rogula- tions and Treaisury Decisions previously Issued. In addition to publishing all Internal Revenue Treasury Decisions and all formal Solicitor's opinions. it is tho'policy of the Bureau of Internal Revenue to publish all rulings and decisions, Including memorandum opinions of the Solicitor of Internal Revenue, which, because they announce a ruling or decision upon a novel question or upon a question in regard to which there exists no previoufty published ruling or decision, or for other reasons, are of such importance an 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 ruling or decision. In many instances memorandum opinions of the Solicitor of Internal Revenue are not of general interest because they announce no new ruling or no now construction of the revenue laws but simply apply rulings already made public to certain situa- tions.of fact which are without special significance. It is not 'the policy of the Bureau to publish such memorandum opinions. Therefore, the numbers assigned to the published memorandum opinions of the Solicitor of Internal Revenue are not consecutive. No unpublished ruling or decision will be cited or relied upon by any officer or employee of the Bureau of Internal Revenue as a precedent in the dis- position of other cases. Unless otherwise specifically indicated, all published rulings and decisions have received the consideration and approval of the Solicitor of Internal Revenue. WASHINGTON GOVERNMENT PRINTING OFFICE 1925

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