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1952-1 C.B. i (1952)

handle is hein.usfed/ircb0064 and id is 1 raw text is: SPECIAL ATTENTION is directed to the cautionary notice on this page that pub- fished 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 1952-1 JANUARY-JUNE 1952 IN THIS ISSUE • Pafle Introductory Notes......... . .HI Contents .............. . . . ... . . V Rulings Nos. 13736-13860- Tax Court of the United States, The . . . . 1-6 Income Tax- Part I (Internal Revenue Code) . ... . . 7-152 Part II (Revenue Act of 1938 and prior Revenue Acts) ...... ..... .......... 153-154 Estate and Gift Taxes .. .. ......... .. 155-172 Employment Taxes .. .. .......... .. 173-206 Excise Taxes ... .............. . 207-225 Miscellaneous Rulings . ............ 227-257 Legislation .. . .............. 259-263 Index .... .................. 265-276 The rulings reported in the Internal Revenue Bulletin are for the information at taxpayers and thei counsel as. showig the tr.end. of ofcial opinon in the administration of the Bureau of Internal Revenue; the rulings other than Treasury Decinions have none of the force or effect of Treasury Decisions and do not commit the Department to any interpretation of the law wbirh has not bees formally approved and promulgated by the Secetary of the Treasury. Each ruling embodies the administrative application of the law and Treasury Decisions to the entire state of fact upon which a prtcular case rest. Itis especilly tube noted that the same result will not nee, sarly be reaced in another case uless all the materal facts ar identical with those ol the reprted case. As it is net always feaible to publish a complete statement at the fact underlying each ruling, there can be no assurance that any new ease 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 pubishrd. Offcrs of the Bureau of Internas Revenue are especially cautioned against reac'hing a conclusion in any case merely on the basis of similarity to a published ruling, and should base their iudg met en the application of all pertinent provisions of the law and Treasury Decisions to all the facts in each cas. These rulings should be used as aids is studying the law and its lormal construction as made in the regulations and Treasury Decisions pre- viusy issued. In addition to eublishing aS tnterual Revenue Treasury Decisions, it is the policy of the Bureau of Interns Revenue to publish all rulings and decisions, including opinions of the Chief Counsel for the Bureau of tterual Revenue, which, because they announce a ruling or decision upon a novel question or upon a question in regard to whieh there exists no previously published ruling or decision, or tor other reasons, are of such importance as to he of general interest. It is also the iolicy 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 ore not of general iilterest because they announce no new ruling or new c€onstruction of the revenue laws hot simply apply rulings already made public to certain situations of fact which or without speial significance. It in not the policy of the Bur eau to publish such opinions. Therefore, the numbers assigned to the published opintou of the Chief Counsel Ifr the Bureau of Internal Revenue are not consecutive. Unless otherwise spificaly 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 1952 Foeule by Superiuteadent of Documents, U. S. Government Priuting Office. Washington 25. D. C. See bach of title for pices

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