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1948-1 C.B. i (1948)

handle is hein.usfed/ircb0056 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 forcc and effect
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 1948-1
JANUARY-JUNE 1948
IN THIS ISSUE
Page
Introductory Notes ...          ..............                              III
Contents .................                                                   .V
Rulings Nos. 12722-12841-
Tax Court of the United States, The, formerly United
States Board of Tax Appeals        ........                          1-4
Income Tax-
Part I (A. Internal Revenue Code and B. 1938
Act)   .  .......                    ..     ..  ..   .      5-107
Part 11 (1937 and 1936 Acts)       .......                        108
Part III (1935 and 1931 or Prior Acts j        ..    .       109-111
Employment Taxes ...             ............ .                 113-126
Miscellaneous Taxes-
Estate and Gift Taxes ............ ..                       127-132
Excise Taxes, Stamp Taxes, etc ........ .                   133-142
Miscellaneous Rulings ...           ............ .              143-210
Legislation ....           ............... .                    211-239
Committee reports ..          ............ .                    241-355
Iadex .....             .  .................                         357-364
The rulings reported in the Internal Revenue Bulletin are for the information of taxpayers and their counsel as
showing the trend of official opinion in the administration of the Bureau of Internal Revenue; the rulings other than
Treasury Deeisions 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 b; the Secretary of the
Treasury. Each rulitg embodies the administrative epplicutien of the law and Treasury Decisions to the entire
state of facts upon which a particular ease rests. It is especially to be noted that the same resalt will not cces-
sully be rached in another ease unless all the materl1 facts are identical with those of the reported case. As it is
not always feasible topublish acornplete statement of the facts ua derlyisg each  uling there cnn he nossuranre
that any new case is identical with the repIrted case. As bearing o it this distinction. it maybe observed thet the
rulings published from time to time may appear to reverse a uiags previously published.
Officers of the Bureou of Internal Rtesease are especially cautioned against reaching at conclusion in any casse
merely on lbs basis of similarity to a published ruling, and should bae thei s judgment on the pp.iatios at all
pertinent provisions of the law and Treasury Decisions to all the facts in each case. These rulings should be used
s aids in studying the law and its formal onsucetiou as made in the regulations and Treasury Decisions pre.
vionoly issued.
In addition tI &ublshnt all Internal Revenue Treasury Decisions, il s the pc.cy of the Bren of Internal
Revenue    iso publish  all rulings  nd decisions. ineldig  o ions of the Chief Co nsel fr the Burro  of  lntersal
Revenue, which, because te, announce a ruling or decision uon a nvel question or upon a qestion in regad
to which there exists no previously published rulisg or decision, or for other reasons, ore of such imyortunce as
to be of general interest. ht is alto the policy of e Bureau to publish elI rulings or decisions lahich revoke.
modify, amend, or affct in any manner wahuteser any published ruling or decision. In many instances opinions
of the Chief Counsel for the Btreau 0t Interest Revenue are st of general interest because they announce no
new ruling or new antructiona of the reenue laws but simply appt rolns already made psbic to certaisn
ituntos of fact wh ich are w thout special te gnificance.  It is  et the pa cy oftha Buress to publsh  such opinens.
Therefore, the numbers assigned to the pblished opinions of the Chief Counsel for the Bureau of Internal
Revenue ae not consecautive. No unpublished ruling or decision will be n eed or relied upon by any officer or
employee of the Bureon of Internal Revenue a a  i recedet in the disposition of other e ases. Unless otherwise
specifically indicted. all published llrugs and deisins have received tha onsideration and approval of the
Chief Co  unsel for the Bureau of Internal Revenue.
UNITED STATES GOVERNMENT PRINTING OFFICE :WASHINGTON : 1948
For sale   y the Superintendent of Documents, US. Government Printing Office
Washington, D.C., 20402- Price $1.50

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