Gerald A. and Henrietta V. Rauenhorst - Page 41




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               The Department of the Treasury’s statement of procedural               
          rules, contained in the regulations, provides in relevant part:             
                    (2)  Objectives and standards for publication of                  
               Revenue Rulings and Revenue Procedures in the Internal                 
               Revenue Bulletin.--(i)(a) A “Revenue Ruling” is an                     
               official interpretation by the Service that has been                   
               published in the Internal Revenue Bulletin.  Revenue                   
               Rulings are issued only by the National Office and are                 
               published for the information and guidance of                          
               taxpayers, Internal Revenue Service officials, and                     
               others concerned.                                                      
                         *    *    *    *    *    *    *                              
                    (iii)  The purpose of publishing revenue rulings                  
               and revenue procedures in the Internal Revenue Bulletin                
               is to promote correct and uniform application of the                   
               tax laws by Internal Revenue Service employees and to                  
               assist taxpayers in attaining maximum voluntary                        
               compliance by informing Service personnel and the                      
               public of National Office interpretations of the                       
               internal revenue laws, related statutes, treaties,                     
               regulations, and statements of Service procedures                      
               affecting the rights and duties of taxpayers.  * * *                   
                         *    *    *    *    *    *    *                              
                    (v)  * * *                                                        
                         *    *    *    *    *    *    *                              
                         (d)  Revenue Rulings published in the                        
                    Bulletin do not have the force and effect of                      
                    Treasury Department Regulations (including                        
                    Treasury decisions), but are published to provide                 
                    precedents to be used in the disposition of other                 
                    cases, and may be cited and relied upon for that                  
                    purpose.  * * *                                                   
                         (e)  Taxpayers generally may rely upon                       
                    Revenue Rulings published in the Bulletin in                      
                    determining the tax treatment of their own                        
                    transactions and need not request specific rulings                








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