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![handle is hein.usfed/ircb0057 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 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 1948-2
JULY-DECEMBER 1948
IN THIS ISSUE
Page
Introductory Notes .... . . ............ I
Contents ......... ................ V
Rulings Nos. 12842-12998-
Tax Court of the United States, The, formerly United
States Board of Tax Appeals 1-6
Income Tax-
Part I (Internal Revenue Code) . .. ... . 7-130
Part II (Revenue Act of 1938 and prior Revenue
Acts) ..... . . ............. . 131-133
Employment Taxes .. . ........... 135-152
Miscellaneous Taxes-
Estate and Gift Taxes ......... 153-156
Excise Taxes, Stamp Taxes, etc . . . . . . 157-206
Miscellaneous Rulings ... ........... 207-316
Legislation ..... ............... 317-324
Index ....... . ................. 325-334
The rulings reported in the Internal Revenue Bulletin are for the information of taxpayers and their counsel as
showing the trent; 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-
e-ily 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 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 bearing out this distinction, 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 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 shoald be use]
as aids in studying the law and its formal construction as made in the regulations and Treasury Decisions pre-
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 opinions of the Chief 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 Chief Counsel for the Bureau of Internal Revenue are not of general interest because they annoance no
new ruling or new construction of the revenue laws but simply apply rulings already made public to certai
situations of fact which are without special significance. It is 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 any officer or
employee of the Bureau of Internal Revenue as a precedent in the disposition of other cases. Unless otherwise
specifically indicated, all published rulings and decisions have received the consideration and approval of the
Chief Counsel for the Bureau of Internal Revenue.
UNITED STATES GOVERNMENT PRINTING OFFICE : WASHINGTON : 1949
For sale by Superintendent of Documents, U. S. Government Printing Office. Washington 25. D. C.
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