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1926 V-2 C.B. [i] (1926)

handle is hein.usfed/ircb0015 and id is 1 raw text is: SPECIAL ATTENTICON             is directed to the cautionary notice on this page that published
rulings of the Bureau do not have the force and effect of
Treasury Docisiono and that they are applicable only to the facts presented in the published case.
Treasury Department                              Bureau of Enternal Revenue
Iumu        tive       u  lThn V-2
JULY-DECEMBER, 1926
IN THIS ISSUE
Page
Rulings Nos. 2814-3026-
Income Tax-
Part I (1.926 Act) ..   ......... .          1-107
Part 11 (1924 Act) ..   ......... .        108-127
Part 111 (1921 and Prior Acts) ....... ..128-214
Sales Tax .....        .............           215-227
Estate Tax .....       ............. .       228-254
Miscellaneous Tax .....         .......... 255-261
Miscellaneous ...       ...........             262-296
The rulft reported in the Internal Revenue Bulletin are for the information of
taxpayers and their counsel as showima the trend of official opinion in the administra-
tion of the Bureau of Internal Revenue; the rulings other than Treasury Deciione
have none of the force or effect of Treasury Decisions and do not commit the Depart-
ment to any Interpretation of the law which has not been formally approved and pro-
mnlgated by the Secretary of the Treasury.  Each ruling embodies the administrative
appiication of the law and Treasury Decisions to the entire state of facto upon which
a particular case rests. 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 ie not always feasible to publish a complete state-
ment of the facto underlying each ruling. there can be no assurance that any new cese
is Identical with the reported case. As bearing out this distinction, it may be observed
that Ilie rulings published from time to time may appear to reverse rulings previously
published.
Officero of the Bureau of Internal Revenue ore especially cautioned against reaching
a conclusion in any case merely on the basis of similarity to a published ruling, and
should base their Judgment on the application of all pertinent provisions of the law
and Treasury Decisions to all the facts In each case. These rulings should be used ao
aids in studying the low and its formal conetruction ao made in the regulations and
Treasury Decisions previously issued.
In addition to publishing all Internal Revenue Treasury Decisions, it io the policy
of the Bureau of Internal Revenue to publish all rulings and decisions, including
opinions of the General Counsel for the Bureau 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 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 ruling or decision.  In many Instances opinions
of the General Counsel for the Bureau of Internal Revenue are not of general interest
because they announce 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 with-
out special signlficance.  It io not the policy of the Bureau to publish ouch opinions.
Therefore, the numbers assigned to the published opinions of the General Counsel for
the Bureau 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 In-
ternal Revenue as a precedent in the disposition of other cases. Unless otherwise
specifically indicated, all published rulings and decisions have received the considera-
tion and approval of the General Counsel for the Bureau of Internal Revenue.
U. S. GOVERNMENT PRINTING OFFICE

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