Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases.In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same.Commentators noted that some penalties are not related to any tax for which a return is required. Congress differentiated these arrangements from situations in which a partner receives an allocation (or increased allocation) for an extended period to reflect its contribution of property or services to the partnership, such that the partner receives the allocation in its capacity as a partner. Section 1.707–1 sets forth general rules on the operation of section 707.
Section 6402 of the Code authorizes the Secretary to make credits or refunds of overpayments.
The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin.
All published rulings apply retroactively unless otherwise indicated.
This document contains final regulations for filing a claim for credit or refund.
The regulations provide guidance to taxpayers generally as to the proper place to file a claim for credit or refund.