IRS Written Determinations
Instructions: More Information:

IRS Written Determinations are documents the IRS is required to make "...open to public inspection..." pursuant to the provisions of I.R.C. Sec. 6110. The documents prepared for release each week are made available to the public every Friday morning, and can either be retrieved from the list below or directly from the https://www.irs.gov/pub/irs-wd/ folder.

More about Written Determinations

IRS Written Determinations do not contain proprietary ("Official Use Only") information. However, it is important to note that pursuant to 26 USC § 6110(k)(3) such items cannot be used or cited as precedent.

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200011008 2516.00-00 Certain Property Settlements (Exempt v. Not Exempt From Gift Tax) 03/17/2000
200221021 2516.00-00 Certain Property Settlements (Exempt v. Not Exempt From Gift Tax) 05/24/2002
200221042 2516.00-00 Certain Property Settlements (Exempt v. Not Exempt From Gift Tax) 05/24/2002
200333013 2516.00-00 Certain Property Settlements (Exempt v. Not Exempt From Gift Tax) 08/15/2003
200408015 2516.00-00 Certain Property Settlements (Exempt v. Not Exempt From Gift Tax) 02/20/2004
200728026 2516.00-00 Certain Property Settlements (Exempt v. Not Exempt From Gift Tax) 07/13/2007
201206005 2516.00-00 Certain Property Settlements (Exempt v. Not Exempt From Gift Tax) 02/10/2012
199932024 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 08/13/1999
200023036 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 06/09/2000
200025012 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 06/23/2000
200025013 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 06/23/2000
200025014 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 06/23/2000
200025015 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 06/23/2000
200025016 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 06/23/2000
200105009 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105010 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105011 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105012 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105013 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105015 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105016 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105017 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105018 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105019 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105020 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105021 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105022 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105024 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105025 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105026 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200105027 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/02/2001
200118039 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/04/2001
200118040 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/04/2001
200118041 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/04/2001
200119008 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/11/2001
200303017 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 01/17/2003
200303018 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 01/17/2003
200303019 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 01/17/2003
200332002 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 08/08/2003
200345007 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 11/07/2003
200507001 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/18/2005
200518049 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/06/2005
200544018 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 11/04/2005
200708010 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/23/2007
200708011 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/23/2007
200709019 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200709020 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200709021 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200709022 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200709023 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200709024 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200709025 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200709026 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200709027 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200709028 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200709029 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200709030 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200709031 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200709032 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200709033 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200709034 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/02/2007
200711008 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/16/2007
200711009 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/16/2007
200711011 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/16/2007
200711012 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/16/2007
200711013 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/16/2007
200711016 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/16/2007
200712019 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/23/2007
200718005 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/04/2007
200718006 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/04/2007
200718007 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/04/2007
200718009 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/04/2007
200718010 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/04/2007
200726012 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 06/29/2007
200726013 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 06/29/2007
200740010 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 10/05/2007
200845035 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 11/07/2008
200848018 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 11/28/2008
200909006 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/27/2009
200919019 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/08/2009
200921010 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/22/2009
201005018 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 02/05/2010
201016026 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 04/23/2010
201132012 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 08/12/2011
201213004 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/30/2012
201232020 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 08/10/2012
201233009 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 08/17/2012
201236023 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 09/07/2012
201250014 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 12/14/2012
201313014 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/29/2013
201316005 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 04/19/2013
201322024 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/31/2013
201330026 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 07/26/2013
201330027 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 07/26/2013
201336016 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 09/06/2013
201338035 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 09/20/2013
201340011 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 10/04/2013
201411004 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/14/2014
201414004 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 04/04/2014
201417005 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 04/25/2014
201418021 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/02/2014
201514003 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 04/03/2015
201523018 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 06/05/2015
201527039 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 07/03/2015
201541009 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 10/09/2015
201549013 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 12/04/2015
201614004 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 04/01/2016
201636039 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 09/02/2016
201651008 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 12/16/2016
201710019 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 03/10/2017
201722023 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 06/02/2017
201818001 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/04/2018
201819001 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 05/11/2018
201822002 7704.00-00 Certain Publicly Traded Partnerships Treated as Corporations 06/01/2018
200026016 845.00-00 Certain Reinsurance Agreements 06/30/2000
200027008 845.00-00 Certain Reinsurance Agreements 07/07/2000
200603011 2209.00-00 Certain Residents of Possessions Considered Nonresident; Not Citizens of the United States 01/20/2006
200752016 2209.00-00 Certain Residents of Possessions Considered Nonresident; Not Citizens of the United States 12/28/2007
200105048 2209.00-00 Certain Residents of Possessions Considered NonresidentD Not Citizens of the United States 02/02/2001
200303015 2209.00-00 Certain Residents of Possessions Considered NonresidentD Not Citizens of the United States 01/17/2003
200848014 2209.00-00 Certain Residents of Possessions Considered NonresidentD Not Citizens of the United States 11/28/2008
200105048 2501.06-00 Certain Residents of Possessions Considered Nonresidents Not Citizens of U.S. 02/02/2001
200303015 2501.06-00 Certain Residents of Possessions Considered Nonresidents Not Citizens of U.S. 01/17/2003
199919009 2704.02-00 Certain Restrictions on Liquidations Disregarded 05/14/1999
200049003 2704.02-00 Certain Restrictions on Liquidations Disregarded 12/08/2000
200143004 2704.02-00 Certain Restrictions on Liquidations Disregarded 10/26/2001
199924015 2703.00-00 Certain Rights and Restrictions Disregarded 06/18/1999
199927002 2703.00-00 Certain Rights and Restrictions Disregarded 07/09/1999
199952012 2703.00-00 Certain Rights and Restrictions Disregarded 12/31/1999
200010015 2703.00-00 Certain Rights and Restrictions Disregarded 03/10/2000
200015012 2703.00-00 Certain Rights and Restrictions Disregarded 04/14/2000
200103038 2703.00-00 Certain Rights and Restrictions Disregarded 01/19/2001
200122024 2703.00-00 Certain Rights and Restrictions Disregarded 06/01/2001
200348006 2703.00-00 Certain Rights and Restrictions Disregarded 11/28/2003
200407006 2703.00-00 Certain Rights and Restrictions Disregarded 02/13/2004
200625011 2703.00-00 Certain Rights and Restrictions Disregarded 06/23/2006
201536009 2703.00-00 Certain Rights and Restrictions Disregarded 09/04/2015
199907005 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 02/19/1999
199909015 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 03/05/1999
199915041 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 04/16/1999
199915046 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 04/16/1999
199916017 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 04/23/1999
199916051 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 04/23/1999
199919023 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 05/14/1999
199920035 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 05/21/1999
199920039 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 05/21/1999
199921019 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 05/28/1999
199924021 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 06/18/1999
199924030 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 06/18/1999
199925037 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 06/25/1999
199930033 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 07/30/1999
199931013 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 08/06/1999
199932025 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 08/13/1999
199933031 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 08/20/1999
199933036 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 08/20/1999
199934012 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 08/27/1999
199935052 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 09/03/1999
199940009 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 10/08/1999
199940010 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 10/08/1999
199941022 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 10/15/1999
199941025 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 10/15/1999
199942027 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 10/22/1999
199942029 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 10/22/1999
199943018 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 10/29/1999
199943020 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 10/29/1999
199945036 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 11/12/1999
199946013 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 11/19/1999
199947014 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 11/26/1999
199948012 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 12/03/1999
199951036 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 12/24/1999
199952030 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 12/31/1999
200001024 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 01/07/2000
200001032 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 01/07/2000
200002012 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 01/14/2000
200007019 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 02/18/2000
200008004 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 02/25/2000
200008022 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 02/25/2000
200008033 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 02/25/2000
200008042 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 02/25/2000
200013028 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 03/31/2000
200014015 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 04/07/2000
200017026 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 04/28/2000
200018004 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 05/05/2000
200020039 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 05/19/2000
200020052 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 05/19/2000
200021029 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 05/26/2000
200021047 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 05/26/2000
200029041 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 07/21/2000
200033041 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 08/18/2000
200037019 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 09/15/2000
200043021 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 10/27/2000
200043022 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 10/27/2000
200043023 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 10/27/2000
200043024 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 10/27/2000
200043025 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 10/27/2000
200251009 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 12/20/2002
200422003 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 05/28/2004
200447004 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 11/19/2004
200703021 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 01/19/2007
200726025 338.00-00 Certain Stock Purchases Treated as Asset Acquisitions 06/29/2007

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