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1945 C.B. i (1945)

handle is hein.usfed/ircb0051 and id is 1 raw text is: SPECIAL ATTENTION is directed to the cautionary notice on this page that pub- lished rulings of the Bureau do not have the force and eflect of Treasury Decisions and that they are applicable only to facts presented in the published case Treasury Department Bureau of Internal Revenue Internal Revenue Bulletin Cumulative Bulletin 1945 JANUARY-DECEMBER 1945 IN THIS ISSUE page Introductory Notes I............. m Contents . .............. V-VII Rulings Nos. 11917-12200- Tax Court of the United States, The, formerly United States Board of Tax Appeals . 1-9 Income Tax- Part I (A. Internal Revenue Code and B. 1938 Act) .. .. ........... 10-352 Part II (1937 and 1936 Acts) . . ..... . 353-366 Part El (1935 and 1934 or Prior Acts) .... 367-368 Employment Taxes .. ............ . 369-380 Miscellaneous Taxes- Estate'and Gift Taxes . ......... . 381-429 Sales Taxes, Stamp Taxes, etc ... ....... 430-458 Miscellaneous Rulings . ........... 459-529 Legislation ... ............... 530-564 Committee Reports .. ............ 565-657 Index ..... .................. 659478 The rulings reported in the Internal Revenue Bulletin are for the information of taxpayers end their counsel as showing the trend of official opinion in the administration 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 Department to any interpretation of the law which has not been formally approved and promulgated by the Secretary 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 rests. It is especially to be noted that the same result will not neces- sarily be reached in another case unless all the materia' tarts are identical with those of the reported case. As it is not always feasible to publish a complete statement of the facts underlying each ruling, there can be no assurance that any new case is identical with the reported case. As hearing out this distincton, it maybe observed that the rulings published tram time to time may appear to reverse rulings preIiously published. Offcers ef the Bureau of Internal Revenue are especially cautioned against reaching a conclusion in any case merey n the basis of similarity to a published ruling, and should base their judgment on te application of all pertonet provssons of the law and Treasury Decisions to all the facto in each case. These ruligs should be used as ds in studying the law and its for m rto sade i the regulations and Treasury Desons pr viously issued. In addition to publishing all Internal Revenue Treasury Decisions, it is the policy of the Bureau of Internal Revenue to publish all rulings and decisions, including oinions of the Chief Counsel for the Bureau of Internal Revenue, which, because they announce a ruling or decision upon a novel qeetion or upon a question in regard to which there exists no prevsously publisbed 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, an a c n any manner whatever any published ruling or decision. In many instances opinions of the Chief Counsel for the Bureau of Internal Revenu e not of general interest because they announce no new ruling or new construction of the revenue laws but simply apply rulings already made public to certain situations of fact which axe without special significance. Itis not the policy of the Bureau to publish such opinions. Therefore, the numbers assigned to the published opinions of the Chief Counsel for the Bureau of Internal Revenue are not consecutive. No unpublished ruling or decision will be cited or relied upon by anyoicer or employee of the Bureau of Internal Revenue as a precedent in the disposition of other cases. unless otherise RpeRfically indicated. #11 publshed rulings and decssions have received the consideration and approval of the Chief Counsel f or the Burea u of Internal Revenue. UNITED STATES GOVERNMENT PRINTING OFFICE :WASHINGTON : 1946 For sale by Superintendent of Documents. U. S. Government Printing Office. Washington 25, D.t. Price $1.75

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