In two letter
rulings, (1) two unrelated entities were tenants-in-common as to certain real estate.
Other individuals and groups, however, were ready to discuss the ramifications of the Supreme Court's
ruling in Gonzales v.
In the
ruling, the taxpayers' two children were diagnosed with disabilities caused by medical conditions (including dyslexia) that handicapped their ability to learn.
In this letter
ruling, it seems clear that the service relied upon the fact that part of the taxpayer's intent was to hold the property as an investment, although you might conclude that this motivation was secondary to their desire to own the property for personal enjoyment (because each time it mentioned the reasons for owning the property, enjoyment was always mentioned as the first reason).
The IRS also has never issued any private letter
rulings or other legal memoranda discussing or applying Rev.
Quoting the Court's own previous
rulings, the judges easily conclude that the answer to these three aspects is No.
A number of higher education and legal organizations have announced conferences throughout the summer and fall to examine how the court's
rulings will affect admissions policies in coming years.
Stay tuned for future
rulings in this complex area of family and tax law.
These journals reconstructed the
rulings and the grounds on which they were based at every step of the judicial ladder.
"They're two different
rulings on two different laws," says Evan Wolfson, an attorney at Lambda Legal Defense and Education Fund who represented James Dale in his challenge to the Scouts in New Jersey.
According to the
ruling, Section 16(b) is triggered by either a "purchase and sale" or a "sale and purchase" of a security within a period of less than six months by an officer, director or greater-than-10% owner of the corporation.
While petition drives might sway an elected legislator, judges are expected to base their
rulings on the Constitution and the laws of the United States and not be influenced by pressure campaigns.
Specifically, in Revenue Procedure 2003-48, the Internal Revenue Service announced a one-year pilot program under which it will no longer issue advance
rulings on key issues arising under -section 355.
In its five-to-four decision on June 23, the Court declared that minor
rulings since 1985 (Witters and Zobrest) had changed the Court's approach on parochial school aid, warranting a reexamination of the 1985
rulings.
