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1940-1 C.B. i (1940)

handle is hein.usfed/ircb0043 and id is 1 raw text is: SPECIAL ATTENTION is directed to the aionary ce on this page that pub- .... .... .. ished rulings of the Burea 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 : i : : : Bureau of Internal Revenue Internal Revenue Bulletin Cumulative Bulletin 1940-1 JANUARY-JUNE, 1940 IN THIS ISSUE Pate Introductory Notes 11..... ....... Contents . .. ........ . V-VII Rulings Nos. 10127-10304-- Board of Tax Appeals .. .. ....... . 1-9 Income Tax- Part I (A. Internal Revenue Code and 1939 Act; B. 1938 Act) ... .. .......... ... 11-94 Part H (1937 and 1936 Acts) ....... 95-104 Part HI (1935 and 1934 or Prior Acts) . . . 105-188 Employment Taxes .. ............ . 189-219 Miscellaneous Taxes- Estate and Gift Taxes . . . .. .. . 220-235 C *tal Stock Taxes ... ......... ... 236-246 S= Taxes (Alcohol, etc.) . . . . . . o.. 247-268 Miscellaneous Rulings .. .. ......... ... 269-323 Index ...... .. ................ . 325-335 The ruling reported in the Internal Revenue Bulletin are for the information of taxpayers and their counsel as ahewig the trendo official opinion in the administration of the Bureau ot Internal Revenue; the rulings other than Treasury Decioiono have none of the force or effect of Treasury Decisions and do not commit the Department to amy interpretation of the law which has not been formally approved and promulgated by the Secretary of the Treasury. Each raling embodies the administrative application of the law and Treasury Decisions to the entire atate of facts upon which a particular case rests. It is especially to be noted that the same result will not neces- earily 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 rulngs 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. tient 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 iued. In addition to publishing all Internal Revenue Treasury Decisions, it is the policy of the Bureau of Internal Revenue to publish al rulings and decisions, including opinions of the Chief Counsel for the Bureau of Internal Revenue, which, because 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 resons, are of such importance as to be of general interest. It is also the policy of the Burneu 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 are not of general interest because they announce as new ruling or no now construction of the revenue laws but simply apply rulins already made public to certain situations of fact which are without special significance. It is not the policy of the Vareas to publis such opinions. Therefore, the numbers assigned to the published opiuions of the Chief Counsel for the Bureau of Internal Revenue are not consecutive. No unpublished ruling or decision will be cited or relied upon by any officer remploee of the Bureau of Internal Revenue as a precedent in the disposition of other cases. Unless otherwise specificaly indicatd, all published rulings and decisions have received the consideration and approval of the Chie Counsel for the Bureau of Internal Revenue. UNITED STATES GOVERNMENT PRINTING OPPICE: WASHINGTON : 1940 For sale by the Superintendent of Documents, U. S. Government Printing Office Washington 25, D. C. - Price $1.00

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