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1933 XII-1 C.B. i (1933)

handle is hein.usfed/ircb0028 and id is 1 raw text is: SPECIAL ATTENTION is directed to the cautionary notice on thispage 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 XII-1
JANUARY-JUNE, 1933
IN THIS ISSUE

Introductory Notes ... ...........
Contents ....   ...............
Rulings Nos. 5962-6262-
Board of Tax Appeals ..........
Income Tax-
Part 1 (1932 Act) ..........
Part H (1928 Act). .......
Part I1 (1926 and Prior Acts). . .
Estate Tax . . . ............
Sales Tax ...  .............
Capital Stock Tax  ........
Miscellaneous ... ...........
Index .....    ...............

Page
III
V-VIn
1-24

.... .           25-90
91-156
.... .        157-353
.....         354-378
.379-467
.468-474
..... 475-490
.....         491-506

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 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-
sarily 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 per-
tinent provisions of the law and Treasury Decisions to all the facts in each case. These rulings should be used as
aids in studying the law and its formal construction as made in the regulations and Treasury Decisions previously
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 General Counsel for the Bureau of Internal Resenue,
which, bemuse 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 General
Counsel for the Bureau of Internal Revenue are not of general interest because they announce no new ruling or no
new construction of the revenue laws but simply apply ralings already made public to certain situations of fact which
are without special sigaificance. It is not the policy of the Bureau to publish such opinions. Therefore, the numbers
assigned to the published opinions of the General 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 General Counsel for the Bureau of
Internal Revenue.
UNITED STATES GOVERNMENT PRINTING OFFICE, WASHINGTON: 1933
For sale by the Superintendent of Documents, Washington, D. C.                         See back of title for prices

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