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1951-1 C.B. i (1951)

handle is hein.usfed/ircb0062 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 1951-1 JANUARY-JUNE 1951 IN THIS ISSUE Page Introductory Notes ...... .. ............ Il Contents . . . .... ..1.4. . . V Rulings Nos. 13509-13614- Ta8 Court of the United States, The .. .... .1-4 Income Tax- Part I (Internal Revenue Code) . ...... 5-67 Estate and Gift Taxes . .........69.-$6 Em~loyment Taxes ............ 87-140 Excise Taxes- Stamp Taxes, etc .... .......... ... 141-154 Miscellaneous Rulings- • ........... 155-175 Legislation ..... 177-185 Committee Reports . ... ......... ... 187-278 Index... . . . .... . ........... . 279-288 The rulings reported In the Internal Revenue Bulletin are for the information of taxpayers and their counsel as showing the trend of official oion in the administration of the Bureau of Internal Revenue; th j rulings other than Treasury Decisions have none of the force or effect of Treasury Doioiena and do not commit the Department to any interpretation of the low which has not been formally approved and promulgated by the Stcretary of the Treasury., Each ruling embodies the administrative application of the low and Treasury Decisions to the entire state of scto upon which a particular case rests. It is aspocial to be noted that the same result will not nees. sarily be reached in another came unless all the material facts are identical with those of the reported cas. As it is not always feasible to publish a coimplte statement of the faote undirlying each ruling, there can be no assurance that any new eas is identical with the reported Case. Am bearing out this distlnction, it may be observed that the rulings published from time to time may appear to reverse rullngs previously published. Officaer of the Bureau of Internal Revenue are especial coot ned against reaching a concluson In any case merely on the bails of similarity to a published ruling, and should base their Judgment on the application of all pertnent provisions of thelaw sod Treamory Decimion to all the facts In each case. Thie rulings should be used as eads In studying the law and Its forma' construction em made In the regulations and Treasury Decisions pre. viously Issued. In addition to publihing all Internal Revenue Troasury Doecions, It Is the pollcy of the Bureau of Internal Revenue to publish eli rul ags and decisions, Including op nlons of the Chief Counso for the Bureau of Internal Revenue, which. because they announce a raling or decision upon a novel question or upon a question In regard to ,h*eh there exists no proviously published ruIn, or decision, or for other reasons, ara of such Imyortance am to be of general tnteroat. It Is also the policy of the BarOu to publish all rulings or decisions whi'ch revoke, modifybamend, or eact in any mannr whatever any publishad rullnl or do~olon. in many instances opinions of the Chief Counsel for the urau of Internal Re venue are not of goneral interest because they announce no new ruling or new construction of the revenue lawo but simply apply cunts already mode pu'blic to certain situations of fact which are without special algltfcanco. It is not the polecy of thu Dcreou to publih such opinons. Therefore, the numbers assigned to the yublished opinions of the Chtof Counsel for the Burea u of Internal Reovenue ore net onseauive. No npublished ruing or decision will be cited or relied upon by any ofier or employee of the Bureau of Isternal Revenue aso precedent Ia the disposition of ether cases. Unless otharwl nocifclly indicated, all published rulings and decisions hove received the consideretion and approval of the ChIef Counsel for the Bureau of Internal Revenue. UNITED STATES GOVERNMENT PRINTING OFFICE m WASHINGTON m 1931 For sale by the Superintendent of Documents, U.S. Government Printing Office Washington, D.C., 20402 - Price $1.25

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