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Treasury Department : : Bureau of Internal Revenue Service,

Cumulative Bulletin

No. 4
JANUARY-JUNE, 1921
INCOME TAX RULINGS
Nos. 1369–1710, Inclusive

THE INCOME TAX RULINGS constitute a service of information from which taxpayers and their counsel may obtain the best available indication of the trend and tendency of official opinion in the administration of the income and profits tax provisions of the Revenue Acts. The rulings have none of the force or effect of Treasury Decisions and do not commit the Department to any interpretation of law which has not been formally approved and promulgated by the Secretary of the Treasury. Each ruling embodies the administrative application of the law and Treasury Decisions to the entire state of facts upon which a particular case arises. Itis especially to be noted that the same result will not necessarily be reached in another case unless all the material facts arei dentical with those of the reported case. Asitis not always feasible to publish a complete statement of the facts underlying each ruling, there can be no assurance that any new case isi dentical with the reported case. As bearing out this distinction, it may be observed that the rulings 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 Income Tax Ruling, and should base their judgment on the application of all pertinent provisions of the law and Treasury Deci. sions to all of the facts in each case. The lacome Tax Rulings should be used merely as aids in studying the law and the Treasury Decisions.

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|THE INCOME TAX BULLETIN SERVICE for 1921,

I consisting of weekly Bulletins of income tax rulings, bimonthly Digests of rulings published in the weekly bulletins, and semiannual Cumulative Bulletins containing in full the rulings in the weekly bulletins published during the previous six months may be obtained by subscription for $2.

THE BIMONTHLY DIGESTS will contain digests of 1921 rulings only, with the exception of the last Digest for 1921, which will include digests of all rulings published in 1919, 1920, and 1921.

NEW SUBSCRIBERS and others desiring to obtain the 1919 and 1920 service should inquire of the Superintendent of Documents for prices of Digest of Income Tax Rulings No. 13 (December, 1920), and Cumulative Bulletins No. 1 (December, 1919), No. 2 (June, 1920), and No. 3 (December, 1920).

ALL INQUIRIES AND SUBSCRIPTIONS should be sent to the Superintendent of Documents, Government Printing Office, Washington, D. C.

PREFACE.

Cumulative Bulletin No. 4 contains in full the rulings of the Department relating to income and profits taxes published in the weekly bulletins of income tax rulings (1-21 to 26–21) for the period January 1, 1921, to June 30, 1921. It should be retained, as its contents will not be reprinted in any subsequent volume. Cumulative Bulletins Nos. 1, 2, 3, and 4 contain in full the rulings published in the income tax bulletin service from its inauguration April 1, 1919, to June 30, 1921.

The rulings are grouped under the sections of the Revenue Act of 1918 and the articles of Regulations 45 to which they relate. The number and the class of each ruling are indicated by numerals and abbreviations. For example, 36-20-1189; Sol. Op. 60, means Solicitor's Opinion 60 which is ruling 1189 and was first published in Bulletin 36 of the 1920 income tax bulletin service.

The following abbreviations are used in this volume:
A, B, C, etc.=The names of individuals.
A. R. M.=Committee on Appeals and Review Memorandum.
A. R. R.=Committee on Appeals and Review Recommendation.
C. B.=Cumulative Bulletin.
Ct. D.=Court Decision.
Dept. Cir.=Department Circular.

M, N, X, Y, etc.=The names of corporations, places, or businesses, according to context. Mim.=Mimeograph Letter. 0, D.=Office Decision. 0. or L. 0.=Solicitor's Law Opinion. Op. A. G.=Opinion of Attorney General. S.=Solicitor's Memorandum. Sol. Op.=Solicitor's Opinion. T. B. M.=Advisory Tax Board Memorandum. T. B. R.=Advisory Tax Board Recommendation. T. D.=Treasury Decision.

is used to represent a certain number, and when used with the word doilars” represents a sum of money.

Rulings of any particular class may readily be located by referring to the Contents, while the Index will enable the reader to locate rulings on any particular subject.

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CONTENTS.

[graphic]

203

366
371

67
367
391
369
311
156

32

157

396

405

379

193

27

392

159

314-

353

399

17

403

164

362

227

264

355
205
108

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