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1951-2 C.B. i (1951)

handle is hein.usfed/ircb0063 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 torce and effect of Treasury Decisions and that they are applicable only to facts presented in the published case Treasury Department : : : : Bureau of Internal Ievenuk Internal Revenue Bulletin Cumulative Bulletin 1951-2 JULY-DECEMBER 1951 IN THIS ISSUE Paoe Introductory Notes . .. ............ II Contents ....................... V Rulings Nos. 13615-13735- Tax Court of the United States, The ... ....... 1-6 Income Tax- Part I (Internal Revenue Code) ......7-157 Estate and Gift Taxes .... ........159-160 Employment Taxes ............161-204 Excise Taxes .............. 205-219 Miscellaneous Rulings. .......... 221-342 Legislation .......... ......... 343-356 Committee Reports ............ 357-654 Index ..... .................. .. 655-664 The rulings reportedin the Internal Revenue Bulletin are for the informotion of taxpeyers ond ther counsel s showing thetreod of ofllcjalopinoiothe administration of the Bureau of InteroolRevenue; theruliogoshec than Treasury Decisions have none of the force or eaect of Tresoory Deisions and do not commit the Deportsentto Toy interprettion of the low which hen not been forsealy opproved ond prolgated by the Sereory of the Treaoory. Bach roliog embodies the edmioiotrotive application of the low end Treasury Deeiuooo to the entire ste of facts upon hich a particular cse roots. It is copecioll to be noted thot the ase resut will not nere. satily ho resetmedin anotherceaoe unless ellthe materiel feet. acesdentlcol wjth those of thereportedcooe. Aoit is not aiways feasihle to poblisho• comopleto ototesoent of the facts underlyig etch rnlng, there con be no osuratnce thatony new case is detcal with the reportedco se. At bearng out this distinetionit may he observed thot the rAbos pobhohed from time to time moy appear to reterse ruhugo previoly published. Officers of the Burean of Internal Revenue are especially oautioned ogainst r'eaching a €osaclosion in any 000e m er oy on the b ois of sim ilrity to a published ruling, nd should bse the ir udgm ent on the application of ll pertnent provsons of the law nd Treaury Decions to all the factsn eitch cos. These rulngshold be ued as ids in studyig the law nd itS formal costruction en m de in the regulations nd Tresuy Decisins pre- viouoy issued. I addition to pblishinp all pptl Revenue Treesor Decisons. it s the poicy of the cureau of Internal Revenue to publish eli rulingo and decisions, includio'g opsino of the Chief Counsel for the Bureau of Internal Revenue. which, because they, announce a rilingor decisirn uipon a novel question or upon at question in regard to which there edists no prersouoly puhlished ruling or decision. or for other reasno. are of ouch imruro'lco as to be of generol interest. It is also the policy of the Burenu to publish all rulings or decisions which revobe, modify. amend. or affect in ny manser whatever any published ruling or decision. In many instances opiniens of the Chief Counsel for the Bureau of Inte'rnel Revenue are not of general interest because they onsounce no sew rating or new construction of the revenue inwo but simply apply rulings already made public to certain sstuatians of fact which are without special sigoilrance. It is not the policy of the Bureau to publish soob noinioo. Therefore, the numbers assignrd to the published opinions ot the Chief Counsel for the Bureau of lnternal Revenue are not consecutive. No unpublshed ruling or decision will he cited or relied up~on by any officer o~r emptoyee of the Bureau of Internal Revesue as a precedent in the disposition of other cases. Unless otherwise apeciteally indicated, all published rulings and decisions hate received the consideration and approval of the hef Consel for the Bureau of IternalRevenue.. UNITED STATES GOVERNMENT PRINTING OFFICE WASHINGTON :1952 For alc by the Superintendent of Documents, U.S. Government Printing Otice Washington, D.C. 20402 - Price $2.25

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