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2007-57 provides guidance to employers on the use of smartcards or other electronic media to provide qualified transportation fringes under sections 132(a)(5) and (f) of the Code. Procedures relating solely to matters of internal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published. All published rulings apply retroactively unless otherwise indicated.Final regulations under section 1045 of the Code relate to partnerships and their partners. , at the Kansas City Service Center after December 31, 2007. The last Bulletin for each month includes a cumulative index for the matters published during the preceding months.The regulations provide rules regarding the deferral of gain on a partnership’s sale of qualified small business stock (QSB stock) and a partner’s sale of QSB stock distributed by a partnership. The Internal Revenue Service Center at Ogden remains the location for Forms 1098-C filed on or before December 31, 2007. These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period.The Service has expanded its acquiescence program to include other civil tax cases where guidance is determined to be helpful.Accordingly, the Service now may acquiesce or nonacquiesce in the holdings of memorandum Tax Court opinions, as well as those of the United States District Courts, Claims Court, and Circuit Courts of Appeal.
However, “acquiescence” indicates neither approval nor disapproval of the reasons assigned by the court for its conclusions; whereas, “acquiescence in result only” indicates disagreement or concern with some or all of those reasons.The regulations also provide rules for a taxpayer (other than a C corporation) who sells QSB stock and purchases replacement QSB stock through a partnership. The Form 1098-C is an information form used by a donee organization to report a contribution of a qualified vehicle with a claimed value of more than 0. It is the policy of the Internal Revenue Service to announce at an early date whether it will follow the holdings in certain cases. This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.Unlike a Treasury Regulation or a Revenue Ruling, an Action on Decision is not an affirmative statement of Service position.It is not intended to serve as public guidance and may not be cited as precedent.
However, the Service will recognize the precedential impact of the opinion on cases arising within the venue of the deciding circuit.