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1939-1 (Part 1) C.B. i (1939)

handle is hein.usfed/ircb0041 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 1939-1 (PART 1) JANUARY-JUNE, 1939 IN THIS ISSUE Page Introductory Notes .... ......... .. . III Contents. ................. V-VII Rulings Nos. 9655-9896- Board of Tax Appeals ... ........... . 1-69 Income Tax- Part I (Internal Revenue Code and 1938 Act) 71-158 Part II (1937 and 1936 Acts) . . . . ... . 159-210 Part 11 (1935 and 1934 or Prior Acts) . ... 211-282 Employment Taxes. .......... 283-324 Miscellaneous Taxes- Estate and Gift Taxes . . . ....... . 325-342 Capital Stock Tax .. . . . ........ . 343-350 Sales Taxes .. . . . . . ........ . 351-390 Miscellaneous Rulings ... . . . ....... .. 391-431 Index ..... .. . . .............. 433-445 (The committee reports en the Revenue Acts (1913 to 1938. inclusive) will be published as Part 2 of this Cumulative Bulletin) 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- eerily 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 cautoned 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 pnd 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 in t he policy of the Bureau of Ioternal Revenue to publh all rings and decisions, including opinions of the Chief Counsel for the Bureau of Internal Revenue, which. becase they aOunce 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 an to be of general interest. It is also the policy of the Bureau to publish all rulings or decisions which revke, nuiy amend, or affect in any manner whatever any published ruling or decision. In many instances opinions of the Chief Counsel for the Bureau of Iternal Revenue are not ot general interest because they announce no new ruling or no new construction of the revenue laws but simply apply rligs already made public is certain situations of fact which are without special significance. It is not the policy of the Borea to publish ouch opinions. Therefore, the numbers assigned to the published opinions of the Chief Counsel for the Bureau of Internal Revenueae not consecutive. No unpublished ruling or decision will he cited or relied upon by any ocer r employee of the Bureau of Internal Revee as a precedent in the disposition of other cone. Unless otherwise speciieally indicated, all published rulings and decisions have received the consideratiou and approval of the Cinef Counsel for the Bureau of Internal Revenue. UNIlTED STATES GOVERNMENT PRINTING OFFICE: WASHINGTON : 1939 For sale by the Superintenent of Documents, U. S Government Printing Office Washington 2, 1. C. - Price $1.2

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