DEP SIT D BY THE UNITED STATES OF AMERICA INTRODUCTORY NOTES. The Internal Revenue Bulletins for 1948 will be published every other week, and, in addition to all decisions of the Treasury Department (called Treasury Decisions) pertaining to Internal Revenue matters, will contain court decisions, opinions of the Chief Counsel for the Bureau of Internal Revenue, and rulings and decisions pertaining to income, estate, gift, sales, employment, social security, and miscellaneous taxes, as indicated on the title page of this Bulletin. Income tax rulings will be printed in three parts. The rulings in Part I will be printed as Part I, "A" (Internal Revenue Code) and "B" (Revenue Act of 1938), the law headings corresponding with the sections of the Code, as amended, and the 1938 Act, respectively, and the regulations headings corresponding with the section headings of Regulations 111 or 103 and the article headings of Regulations 101. Rulings under the Revenue Acts of 1937 and 1936 will be printed as Part II, the law headings corresponding with the section headings of those Acts and the regulations headings corresponding with the article headings of Regulations 94. Rulings under the Revenue Acts of 1935 and 1934 or prior Acts will be printed as Part III, the law headings corresponding with the section headings of the Revenue Act of 1934 and the regulations headings corresponding with the article headings of Regulations 86. Rulings under Titles VIII and IX of the Social Security Act and under Subchapters A and C, Chapter 9, of the Internal Revenue Code in force prior to January 1, 1940, will be published under article headings of Regulations 91 and 90, respectively; rulings under Subchapters A and C, Chapter 9, of the Code in force on or after January 1, 1940, will be published under the section headings of Regulations 106 and 107, respectively; rulings under the Carriers Taxing Act of 1937 and under Subchapter B, Chapter 9, of the Code will be published under the article headings of Regulations 100; and rulings under Title III of the Revenue Act of 1936-Tax on unjust enrichment-will be coded under the sections of that Act and the article headings of Regulations 95. The new rulings and decisions will be consolidated semiannually and printed separately as Cumulative Bulletins. At the upper right-hand corner of each ruling published in 1948 there will be a key to the ruling, showing the year of publication of the Bulletin, the number of the Bulletin, and the service ruling number, separated by dashes. Directly beneath these numbers are letters characterizing the ruling, followed by the number given to it by the Chief Counsel for the Bureau of Internal Revenue or the unit or division of the Service from which it emanated. Thus: 1948-1-12723 I. T. 3884 indicates Income Tax Office Decision 3884, which appears in Bulletin No. 1, for the year 1948 as service ruling No. 12723. (III) ABBREVIATIONS. The following abbreviations are used throughout the Bulletin: 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. B. T. A.-Board of Tax Appeals. C. B.-Cumulative Bulletin. Ct. D.-Court decision. C. S. T.-Capital Stock Tax Division. C. T.-Taxes on Employment by Carriers. D. C.-Treasury Department circular. E. P. C.-Excess Profits Tax Council ruling or memorandum. E. T.-Estate Tax Division. Em. T.-Taxes imposed by the Social Security Act, the Carriers Taxing Act of 1937, and Subchapters A, B, and C of the Internal Revenue Code. G. C. M.-General Counsel's, Assistant General Counsel's, or Chief Counsel's memorandum. I. R. B.-Internal Revenue Bulletin. I. R. C.-Internal Revenue Code. I. T.-Income Tax Unit. M, N, X, Y, Z, etc.—The names of corporations, places, or businesses, according to context. Op. A. G.-Opinion of the Attorney General. P. T.-Processing Tax Division. S. T.-Sales Tax Division. Sil. Silver Tax Division. S. M.-Solicitor's memorandum. Sol. Op.-Solicitor's opinion. S. R.-Solicitor's recommendation. S. S. T.-Taxes on employment by others than carriers. T. B. M.-Advisory Tax Board memorandum. T. B. R.-Advisory Tax Board recommendation. T. C.-The Tax Court of the United States. T. D.-Treasury Decision. x and y are used to represent certain numbers, and when used with the word "dollars represent sums of money. ANNOUNCEMENT RELATING TO DECISIONS OF THE TAX COURT OF THE UNITED STATES. In order that taxpayers and the general public may be informed whether the Commissioner has acquiesced in a decision of The Tax Court of the United States, formerly known as the United States Board of Tax Appeals, disallowing a deficiency in tax determined by the Commissioner to be due, announcement will be made in the Internal Revenue Bulletin at the earliest practicable date. (No announcements are made in the Bulletin with respect to memorandum opinions of The Tax Court.) Notice that the Commissioner has acquiesced or nonacquiesced in a decision of The Tax Court relates only to the issue or issues decided adversely to the Government. Decisions so acquiesced in should be relied upon by officers and employees of the Bureau of Internal Revenue as precedents in the disposition of other cases. ! The cumulative contents includes all rulings published since January 1, 1948. The figures in the page column refer to the pages of the Bulletin in which the ruling was published. (V) ANNOUNCEMENT OF 1948 BULLETIN SERVICE The Internal Revenue Bulletin service for 1948 will consist of bulletins issued every other week and semiannual cumulative bulletins. The bulletins will contain the rulings and decisions to be made public and all Treasury Department decisions (known as Treasury Decisions) pertaining to Internal Revenue matters. The semiannual cumulative bulletins will contain all rulings and decisions (including Treasury Decisions) published during the previous 6 months. The complete Bulletin service may be obtained, on a subscription basis, from the Superintendent of Documents, Government Printing Office, Washington 25, D. C., for $2.50 per year; foreign, $3.75. Single copies of the Bulletin, 10 cents each. New subscribers and others desiring to obtain the 1919, 1920, and 1921 Income Tax Service may do so from the Superintendent of Documents at prices as follows: Digest of Income Tax Rulings No. 19 (containing digests of all rulings appearing in Cumulative Bulletins 1 to 5, inclusive), 50 cents per copy; Cumulative Bulletins Nos. 1 to 5, containing in full all rulings published since April, 1919, to and including December, 1921, as follows: No. 1,* 30 cents; No. 2, 25 cents; No. 3, 30 cents; No. 4,* 30 cents; No. 5,* 25 cents. Persons desiring to obtain Sales Tax Cumulative Bulletins for July-December, 1921, may procure them from the Superintendent of Documents at 5 cents per copy. Persons desiring to obtain the Internal Revenue Bulletin service for the years 1922 to 1946, inclusive, may do so at prices. as follows: *The asterisk (*) indicates the supply of that publication is exhausted. 1 House, Senate, and conference reports on revenue bills from October 3, 1913, to Revenue Act of 1938, inclusive; and on amendments thereto. Persons desiring to obtain the service in digest form may do so at prices as follows: Digest No. 13 (1922-1924), 60 cents; Digest No. 17* (1925), 25 cents; Digest No. 21* (1926), 15 cents; Digest No. 22 (1925– 1927), 35 cents; and Digest A (income tax rulings only, April, 1919, to December, 1930, inclusive), $1.50. All inquiries in regard to these publications and subscriptions should be sent to the Superintendent of Documents, Government Printing Office, Washington 25, D. C. (VI) RULINGS MADE PUBLIC SINCE BULLETIN 1948-3. SPECIAL ATTENTION is directed to the cautionary notice on the title page that case. ANNOUNCEMENT RELATING TO DECISIONS OF THE TAX COURT OF THE UNITED STATES. The Commissioner does NOT acquiesce in the following decision: |