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Office of Chief Counsel Internal Revenue Service

www.irs.gov

Office of Chief Counsel Internal Revenue Service memorandum CC:LM:RFP:CHI:2:POSTF-151402-01 MJCalabrese date: to: Joe Jason, Internal Revenue Financial Products Specialist, and Pat Perrone, Internal Revenue Agent

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Office of Chief Counsel Internal Revenue Service

www.irs.gov

Office of Chief Counsel Internal Revenue Service Memorandum Number: 200840001 Release Date: 10/3/2008 CC:PA:04 GL-130545-08 UILC: 6321.00-00 date: August 28, 2008 to: Richard T. Cummings General Attorney (Hartford)

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Office of Chief Counsel Internal Revenue Service

www.irs.gov

Office of Chief Counsel Internal Revenue Service Memorandum Number 200709063 : 07 /2/20 3 : Date se Relea CC:PSI:B06: ----- POSTF-145525-05

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Office of Chief Counsel Internal Revenue Service

www.irs.gov

Internal Revenue Service memorandum CC:TEGE:EOEG:ET2:SLHartford FILES-102495-07 . UILC: 61.00-00, 3101.00-00, 3111.00-00, 3402.00-00 . date: October 22, 2008 . to ... require that the payment be in settlement of a claim in order to be excluded from gross income. Section 1.104-1(c) of the Income Tax

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February 13, 2019 Mr. William M. Paul Mr. Scott K ...

www.aicpa.org

1 February 13, 2019 Mr. William M. Paul Mr. Scott K. Dinwiddie Acting Chief Counsel Associate Chief Counsel Internal Revenue Service Income Tax & Accounting

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Office of Chief Counsel Internal Revenue Service

www.irs.gov

POSTU-104922-16 5 executed. In cases like this, the “reformation” appears to be more of a modification. Similarly, in this case, the purpose of the Modification Order was not to resolve a conflict

  Services, Internal, Revenue, Chief, Counsel, Chief counsel internal revenue service

Office of Chief Counsel Internal Revenue Service

www.irs.gov

PRESP-106008-03 3 In The Church in Boston v. Commissioner, 71 T.C. 102 (November 1, 1978), the Tax Court considered, for purposes of the definition of charitable under section 501(c)(3),

  Services, Internal, Revenue, Chief, Counsel, Chief counsel internal revenue service

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