internal_revenue_service number release date index number -------------------------- ------------------------------ -------------------------------- ----------------------- ------------------------------------------ department of the treasury washington dc third party communication none date of communication not applicable_person to contact -------------------------- id no ---------------- ----------------- telephone number --------------------- refer reply to cc corp b05 plr-151249-11 date date legend parent sub1 sub2 sub3 ty ------- ty ------- -------------------------------- ----------------------- ------------------------------- ------------------------------------- ----------------------- --------------------------- ------------------------------- ----------------------- --------------------------- ------------------------- ----------------------- ------------------------------- acquirer ------------------------------------------------ ------------------------------------------------ fsub date date date ----------------------------- -------------------------------------------------------------------------------- ---------------------- ------------------- ------------------- plr-151249-11 date date date -------------------------- -------------------------- -------------------------- dear ---------------- this letter is in response to your letter dated date supplemented by your letter dated date both submitted on behalf of parent requesting that the commissioner make a determination under sec_1_1502-75 of the income_tax regulations that sub1 sub2 and sub3 the subsidiaries have joined in the making of the initial consolidated federal_income_tax return filed by parent for its short taxable_year starting on date and ending on date the short-year return the material information submitted is summarized below summary of facts prior to date parent qualified as an s_corporation and sub1 and sub2 were qualified subchapter_s subsidiaries of parent on date acquirer treated as a partnership for federal_income_tax purposes acquired common_stock in parent as a result of acquirer’s acquisition of parent stock parent’s s status terminated and parent became a c_corporation with sub1 and sub2 becoming separate c corporations for federal_income_tax purposes parent filed a final form_1120s return for parent sub1 and sub2 for the period between date and date on date in a transaction that was not a reverse_acquisition under sec_1_1502-75 sub1 acquired all of the stock of sub3 and fsub sub3 timely filed a separate short- year return for the period between date and date parent filed the short-year return as the parent of an affiliated_group including itself and the subsidiaries together the parent group sub3 joined in the short-year return for the period between date and date the short-year return included all items of income gain deduction loss and credit for the members of the parent group for the period during which they were members of the group however the short-year return did not include form_1122 consents for the subsidiaries or a form_851 affiliations schedule identifying the subsidiaries for taxable years subsequent to the one ending date the parent group filed consolidated_returns including all items of income gain deduction loss and credit for the parent group and which identified the subsidiaries on the form_851 affiliations schedule plr-151249-11 parent has made the following representations representations a b the parent group timely filed the short-year return no member of the parent group filed separate returns for the period such entity was included on the short-year return applicable law sec_1_1502-75 provides in part that a group that did not file a consolidated_return for the immediately preceding_taxable_year may file a consolidated_return in lieu of separate returns for the taxable_year provided that each corporation which has been a member during any part of the taxable_year for which the consolidated_return is to be filed consents in the manner provided in sec_1_1502-75 to the regulations under sec_1502 if a group wishes to exercise its privilege of filing a consolidated_return such consolidated_return must be filed not later than the last day prescribed by law including extensions of time for the filing of the common parent’s return with regard to a corporation’s consent for a group’s first consolidated_year sec_1_1502-75 provides that the consent referred to in sec_1_1502-75 shall be made by such corporation joining in the making of the consolidated_return for such year a corporation shall be deemed to have joined in the making of such return for such year if it files a form_1122 in the manner specified in sec_1_1502-75 sec_1_1502-75 provides that if under the provisions of sec_1 a a group wishes to file a consolidated_return for a taxable_year then a form_1122 must be executed by each subsidiary for the taxable_year to which this ruling is relevant the group must attach either executed forms or unsigned copies of the completed forms to the consolidated_return if the group submits unsigned forms with its return it must retain the signed originals in its records in the manner required by sec_1_6001-1 form_1122 is not required for a taxable_year if a consolidated_return was filed or was required to be filed by the group for the immediately preceding year sec_1_1502-75 provides that if a member of the group fails to file form_1122 the commissioner may under the facts and circumstances determine that such member has joined in the making of a consolidated_return by such group the circumstances among others that will be taken into account in making this plr-151249-11 determination include i whether or not the income and deductions of the member were included in the consolidated_return ii whether or not a separate_return was filed by the member for that taxable_year and iii whether or not the member was included in the affiliations schedule form_851 if the commissioner determines under the facts and circumstances that the member has joined in the making of the consolidated_return such member will be treated as if it had filed a form_1122 for such year for purposes of sec_1_1502-75 ruling based solely on the information submitted and the representations made we rule that for purposes of sec_1_1502-75 each of the subsidiaries shall be treated as if it had filed a form_1122 with the short-year return and thus each shall be treated as having joined in the making of the consolidated_return for such year sec_1_1502-75 caveat the rulings contained in this letter are based upon information and representations submitted by the taxpayer and accompanied by a penalty of perjury statement executed by an appropriate party while this office has not verified any of the material submitted in support of the request for rulings it is subject_to verification on examination except as expressly provided herein no opinion is expressed or implied concerning the tax consequences of any aspect of any transaction or item discussed or referenced in this letter procedural statements this ruling is directed only to the taxpayer requesting it sec_6110 of the code provides that it may not be used or cited as precedent a copy of this letter must be attached to each federal_income_tax return to which it is relevant alternatively taxpayers filing their returns electronically may satisfy this requirement by attaching a statement to the return that provides the date and control number of the letter_ruling plr-151249-11 pursuant to the power_of_attorney on file with this office a copy of this letter is being sent to your authorized representative sincerely _ken cohen________________________ ken cohen senior technician reviewer branch office of associate chief_counsel corporate


internal_revenue_service number release date index number ------------------------------------------------------- ---------------------------------- -------------------------------- --------------------------------------- ---------------------------------------- department of the treasury washington dc third party communication none date of communication not applicable_person to contact -------------------------- id no ---------------- ---------------------------------------------------- telephone number --------------------- refer reply to cc tege eb hw plr-149519-10 date date legend taxpayer -------------------------------------------------- ----------------------------------------------- statute a statute b plan dear --------------- ------------------------------------------------- --------------------------------------------- ----------------------------------- this responds to your letter dated date requesting a ruling concerning the income_tax consequences under sec_104 of the internal_revenue_code the code of disability benefits paid under plan taxpayer adopted plan under statute a and statute b to provide certain benefits for employees who sustain a job-related injury illness or occupational disease arising out of the course and within the scope of employment according to the information submitted an employee injured on duty will receive of the employee’s salary at time of injury for the first six-month period the six-month period may be extended for an additional six months upon taxpayer’s receipt of supplementary medical documentation the employee will receive of salary for the second six-month period sec_104 of the code states that except in the case of amounts attributable to and not in excess of deductions allowed under sec_213 relating to medical etc plr-149519-10 expenses for any prior taxable_year gross_income does not include-- amounts received under workmen's_compensation acts as compensation_for personal injuries or sickness sec_1_104-1 of the income_tax regulations states that sec_104 excludes from gross_income amounts that are received by an employee under a workmen's_compensation_act or under a statute in the nature of a workmen's_compensation_act that provides compensation to employees for personal injuries or sickness incurred in the course of employment sec_104 also applies to compensation which is paid under a workmen's_compensation_act to the survivor or survivors of a deceased employee however sec_104 does not apply to a retirement pension or annuity to the extent that it is determined by reference to the employee's age or length of service or the employee's prior contributions even though the employee's retirement is occasioned by an occupational injury or sickness accordingly based on the representations made and authorities cited above we conclude that benefits paid to an employee under plan are paid pursuant to a statute in the nature of workmen’s compensation and amounts paid under plan are excludable from the employee’s gross_income under sec_104 of the code this ruling is directed only to the taxpayer requesting it sec_6110 of the code provides that it may not be used or cited as precedent sincerely harry beker chief health and welfare branch office of division counsel associate chief_counsel tax exempt government entities


vr z e4-08 date jul department of the treasury internal_revenue_service washington d c contact person id number telephone number ope go-t2 employer_identification_number legend w x y z dear sir or madam this is in reply to your letter of date requesting a five year extension under the provisions of sec_4943 of the internal_revenue_code of the period within which a private_foundation normally is allowed to dispose_of excess business_assets acquired by gift you have been recognized as exempt under sec_50i c of the code and are a private_foundation within the meaning of sec_509 you are the successor to w a private_foundation which was established by x the majority of the assets you hold are shares of stock in y that x had contributed to w in x made an additional_contribution of shares of stock in y to w as a result of this gift w’s holdings in y exceeded the percent de_minimis amount of permitted holdings atlowed by sec_4943 of the code x has made no additional donations of stock to you x is an officer and director of both you and y as founder and a substantial_contributor to w x was a disqualified_person as regards w y is a publically traded corporation control y x and other family members subsequent to w receiving the gift of stock from x you were established w was terminated pursuant to the provisions of sec_507 and all of its assets were transferred to you w had requested and received a ruling from the service regarding its proposed sec_507 substantial_contraction and termination the ruling from the service specifically held among other things that pursuant to the provisions of sec_1_507-3 of the foundation and similar excise_tax regulations you succeeded to the transferors holding periods in sec_4943 and for disposing of excess_business_holdings uf re as noted above after the gift of stock from x w's holdings in y exceeded the level of permissible holdings sec_4943 provided w a 5-year period to dispose any excess_business_holdings this period ended in the year as a result of the termination of w you succeeded to the time remaining in the 5-year period within which the shares in y which w had acquired by gift were to be disposed of z is exempt under sec_501 of the code and is a private_foundation within the meaning of sec_509 z was established by x's son and it also holds a substantial number of shares in y several years after establishing z x’s son made an additional_contribution of shares of stock in y to z x's son is a director of z and an officer of y the information you have submitted indicates that both you and w were actively disposing of shares of stock in y both by sale and by donating blocks of shares to various public_charities however the orderly disposal of the shares was disrupted and the number of shares being distributed was substantially reduced when it appeared that a unrelated third party was purchasing shares in y in an attempt to takeover control of y this jull continued until x could take the necessary actions to ensure the family’s continued control of y furthermore because of the smail number of shares in y which are traded on the stock market you fear that the sale of a block of stock of the size needed to come within the permitted holdings levels of sec_4943 would greatly depress the value of the stock accordingly by the end of the five year period you had been unable to dispose_of a sufficient number of the shares of stock you held in y therefore your holdings in y including the shares held by z exceeded the level of permitted holdings as mentioned above you have requested an extension of the five year period within which a private_foundation is expected to dispose_of any excess_business_holdings it has received by gift prior to the end of the initial five year period you submitted a plan which would have enabled you to dispose_of ail the additional shares of stock you need to dispose_of in order to come within the percent de_minimis holdings level you have represented that a copy of this plan has been submitted to the appropriate state official having administrative or supervisory authority or responsibility with respect to your disposition of the remaining shares of stock as a result of subsequent discussions with representatives of our office you have modified your proposed plan and now expect to dispose_of your excess_business_holdings within one year from the date upon which the initial five year period ended you have indicated that to the extent you are unable to distribute all your excess holdings to qualified recipients the remaining shares shail be sold through the stock market sec_50l c of the code exempts from federal_income_tax organizations organized and operated exclusively for charitable or educational_purposes sec_509 of the code provides that unless specifically excepted a domestic or foreign organization described in sec_50i c is a private_foundation and subject_to the excise_taxes of chapter sec_4943 of the code imposes a tax on the excess_business_holdings of any private_foundation in a business_enterprise during any taxable_year re sec_4943 of the code defines the term excess_business_holdings as meaning with respect to the holdings of any private_foundation in any business_enterprise the amount of stock or other interest in the enterprise which the foundation would have to dispose_of to a person other than a disqualified_person in order for the remaining holdings of the foundation in such enterprise to be permitted holdings sec_4943 of the code provides that the permitted holdings of any private_foundation in an incorporated business_enterprise are i percent of the voting_stock reduced by ii the percentage of the voting_stock owned by ail disqualified persons sec_4943 provides that a private_foundation shall not be treated as having excess_business_holdings in any corporation in which it together with all other private_foundations which are described in sec_4946 h owns not more than percent of the voting_stock and not more than percent in value of all outstanding shares of all classes of stock sec_4943 of the code provides that with certain exceptions not applicable here if after date there is a change in the holdings in a business_enterprise other than by purchase ie by gift or bequest by the private_foundation or by a disqualified_person which causes the private_foundation to have excess_business_holdings in such enterprise the interest of the foundation in such enterprise immediately after such change shall while held by the foundation be treated as held by a disqualified_person rather than by the foundation during the 5-year period beginning on the date of such change in holdings sec_4943 provides that the secretary may extend for an additional year period the period under subparagraph for disposing of excess_business_holdings in the case of an unusually large gift or bequest of diverse business holdings or holdings with complex corporate structures if - a the foundation establishes that - i diligent effort to dispose_of such hoidings have been made within the initial 5-year period and disposition within the initial 5-year period has not been possible except at a price substantially below fair_market_value by reason of such size and complexity or diversity of such holdings b before the close of the initial 5-year period - i the private_foundation submits to the secretary a pian for disposing of all of the excess_business_holdings involved in the extension and ii the private_foundations submits the plan described in clause i to the attorney_general or other appropriate state official having administrative or supervisory authority or responsibility with respect to the foundation's disposition of the excess_business_holdings involved and submits to the secretary any response received by the private_foundation from the attorney_general or other appropriate state official to such plan during such 5-year period and re c the secretary determines that such plan can reasonably be expected to be carried out before the close of the extension period sec_53_4943-4 of the foundation and similar excise_tax regulations provides that in general when the percentage of the holdings in a business_enterprise held by a private_foundation and all disqualified persons together or when the percentage of the holdings of a private_foundation alone in such business_enterprise deceases such holdings may not be increased sec_53_4943-3 of the regulations provide that a private_foundation is not treated as having excess_business_holdings in any incorporated business_enterprise in which it together with all other private_foundations described in sec_4946 actually or constructively owns not more than percent of the voting_stock and not more than percent in value of all outstanding shares of all classes of stock if however the private_foundation together with all other private_foundations described in sec_4946 actually or constructively owns more than percent of either the voting_stock or the value of the outstanding shares of all classes of stock in any incorporated business_enterprise all the stock in such business_enterprise classified as excess_business_holdings under sec_4943 is treated as excess_business_holdings for purposes of this paragraph any stock owned by a private_foundation which is treated as held by a disqualified_person under sec_4943 or shall be treated as actually owned by the private_foundation sec_4946 provides that for the purposes of sec_4943 the term disqualified_person includes a private_foundation which is effectively controlled directly or indirectly by the same person or persons who control the private_foundation in question or one where substantially_all of the contributions were made directly or indirectly by the same persons to include a substantial_contributor or a member of their family the information submitted establishes that x gave you a large number of shares of stock in y and under the provisions of sec_4943 you were required to dispose_of these shares of stock within years in order to avoid being placed in a position of having excess_business_holdings you were unable to dispose_of an adequate number of shares of stock within the allotted five year period accordingly you requested an additional period of time within which to dispose_of these shares you have presented a plan to dispose_of your excess_business_holdings in y within one year from the end of the initial year period it appears that this plan can reasonably be expected to be successfully carried out and at the end of the one year extension period you expect to have disposed of sufficient shares of stock in y to come within the percent de_minimis holdings level accordingly based on the information you have submitted we rule that your plan to dispose_of your excess_business_holdings can reasonably be expected to be carried out before the close of the year after the expiration of the initial five year period within which you are required to dispose_of your excess_business_holdings obtained by gift this ruling is directed only to the organization that requested it sec_6110 of the code provides that it may not be used or cited as precedent because this letter could help resolve any questions about your exempt status you should keep it in your permanent records re if you have any questions about this ruling please contact the person whose name and telephone number are shown in the heading of this letter sincerely viv gestend cartas garland a carter manager exempt_organizations technical group


internal_revenue_service number release date index number ------------------------------------------------------------- ------- -------------------------------------------- -------------------- ----------------------- ---------------------------- department of the treasury washington dc third party communication none date of communication not applicable_person to contact -------------------- id no ----------------- telephone number -------------------- refer reply to cc psi b01 plr-103082-12 date date legend trust -------------------------------------------------- ------------------------------------------------------------------ debtor date date date date date date date date date date ----------------------------- ------------------------ ------------------- --------------------- ------------------ ------------------ --------------------- ------------------ --------------------- ------------------ ------------------ plr-103082-12 a --- dear --------------- this is in response to your letter dated date submitted on behalf of trust requesting a ruling regarding the classification of trust as a liquidating_trust under sec_301_7701-4 of the procedure and administration regulations facts the information submitted states that the debtor filed a voluntary petition under chapter of the bankruptcy code in the united_states bankruptcy court on date on date debtor submitted to the bankruptcy court the plan_of_reorganization the plan on date the plan was confirmed by the bankruptcy court on date trust was established and approved by the bankruptcy court to facilitate the liquidation of the estate the initial term of the trust was for four years ending date on date the bankruptcy court extended the term of the trust by three years ending on date on date the bankruptcy court extended the term of the trust by an additional year ending on date pursuant to the provisions of the trust agreement trust was created for the purpose of liquidating the assets of trust with no objective to continue or engage in the conduct_of_a_trade_or_business except to the extent reasonably necessary to and consistent with the liquidating purpose of trust trust shall not receive or retain cash in excess of a reasonable amount to meet claims and contingent liabilities including disputed claims or to maintain the value of the assets during liquidation cash not available for distribution and cash pending distribution will be held in demand and time deposits such as short-term certificates of deposit in banks or other savings institutions or other temporary liquid investments such as treasury bills trust is required under the terms of trust to distribute to the beneficiaries of trust at least annually its net_income and all net_proceeds from the sale of trust's assets except that trust may retain an amount of net_proceeds or net_income reasonably necessary to maintain the value of the property or to meet claims or contingent liabilities trust provides that the beneficiaries of trust will be treated as the grantors and deemed owners of trust it further provides that the parties will value all assets transferred to trust consistently and use such values for all federal_income_tax purposes trust provides that the trustee of trust shall file tax returns as a grantor_trust pursuant to sec_1_671-4 of the income_tax regulations trust consistent with the requirements set out in revproc_94_45 1994_2_cb_684 provides that the transfer of trust assets to trust will be treated for all federal tax purposes as a deemed transfer by the debtor to the beneficiaries followed by a deemed transfer by the beneficiaries to trust plr-103082-12 as of the date of the request trust had distributed amounts comprising approximately a of the claims in the trust to its beneficiaries trust represents that from its establishment trust has been formed and operated consistent with the conditions set out in revproc_94_45 trust now represents that certain developments generally beyond the control of the trustee of trust have occurred that make it impossible to completely liquidate trust by date the end of its three year extension trust requests a ruling that it will retain its status as a liquidating_trust in compliance with sec_301 d and rev_proc if trust's term is extended by the bankruptcy court for another three years ending on date law and analysis sec_671 of the internal_revenue_code provides that where it is specified in subpart e that the grantor or another person shall be treated as the owner of any portion of a_trust there then shall be included in computing the taxable_income and credits of the grantor or the other person those items of income deductions and credits against tax of the trust that are attributable to that portion of the trust to the extent that such items would be taken into account under chapter of the code in computing taxable_income or credits against the tax of an individual sec_1_671-4 provides that except as provided in sec_1_671-4 and items of income deduction and credit attributable to any portion of a_trust which under the provisions of subpart e sec_671 and following part i subchapter_j chapter of the code are treated as owned by the grantor or another person should not be reported by the trust on form_1041 u s income_tax return for estates trusts but should be shown on a separate statement attached to that form sec_677 provides in part that the grantor shall be treated as the owner of any portion of a_trust whether or not the grantor is treated as such owner under sec_674 whose income without the approval or consent of any adverse_party is or in the discretion of the grantor or a non-adverse party or both may be distributed to the grantor or the grantor's spouse or held or accumulated for future distribution to the grantor or the grantor's spouse sec_301_7701-4 provides that certain organizations which are commonly known as liquidating trusts are treated as trusts for purposes of the internal_revenue_code an organization will be considered a liquidating_trust if it is organized for the primary purpose of liquidating and distributing the assets transferred to it and if its activities are all reasonably necessary to and consistent with the accomplishment of that purpose a liquidating_trust is treated as a_trust for purposes of the code because it is formed with the objective of liquidating particular assets and not as an organization having as its purpose the carrying on of a profit-making business which normally would be conducted through business organizations classified as corporations or partnerships however if the liquidation is unreasonably prolonged or if the liquidation purpose becomes so obscured by business activities that the declared purpose of liquidation can be said to be lost or abandoned the status of the organization will no longer be that of a liquidating_trust plr-103082-12 revproc_94_45 provides the conditions under which the service will consider issuing advance rulings classifying certain trusts as liquidating trusts under sec_301_7701-4 revproc_94_45 states that the service will issue a ruling classifying an entity created pursuant to a bankruptcy plan under chapter of the bankruptcy code u s c sec_1101 et seq as a liquidating_trust under sec_301_7701-4 if certain specified conditions are met conclusions based on the information submitted and the representations made we conclude that the conditions of revproc_94_45 have been satisfied accordingly based on the representations made and the information submitted we rule that trust will be classified for federal_income_tax purposes as a liquidating_trust under sec_301_7701-4 of the regulations therefore trust will be a grantor_trust and the beneficiaries of trust will be treated as the owners of trust under sec_671 and sec_677 additionally an extension of the trust's term to date will not adversely affect the determination that trust is a liquidating_trust under sec_301_7701-4 except as specifically set forth above we express or imply no opinion concerning the federal tax consequences of the facts described above under any other provision of the code this ruling is directed only to the taxpayer requesting it sec_6110 provides that it may not be used or cited as precedent pursuant to a power_of_attorney on file with this office a copy of this letter is being sent to trust's authorized representatives sincerely david r haglund david r haglund chief branch office of the associate chief_counsel passthroughs special industries enclosures copy for sec_6110 purposes copy of this letter cc


internal_revenue_service index no number release date sep cc dom p si - plr-110000-99 trust a b date x state dear this responds to your letter dated date submitted on behalf of trust requesting a ruling under sec_1361 of the internal_revenue_code the information submitted states that trust was established on date by a grantor for the benefit of the living children of the grantor’s child b or failing such living children for the living children of grantor’s other children trust currently holds stock in x a state limited_liability_company the trust trustees propose to contribute trust’s interest in x to a newly formed corporation that will elect s_corporation status in exchange for the stock of the newly formed corporation trust represents that trust has not made an election to be a qualified_subchapter_s_trust trust is not exempt from tax under subtitle a of the code and each trust_beneficiary is an individual article one of trust provides that the trustees shall hold manage invest and reinvest the trust property shall collect the income therefrom and shall pay the net_income in convenient installments in such proportions and with such exclusions as the trustees shall deem advisable among the living children of b or failing such living children at any time of payment among the living children of grantor’s other children or the trustees shall have the right to and are authorized to accumulate any or all of such net_income as they shall deem advisable and add the same to the principal of the trust property any payments of net_income may be made by the trustees either directly to or indirectly in trust or otherwise for the benefit of the beneficiary concerned article one further provides that in the event that any payment of income authorized under article one to any individual beneficiary shall be insufficient in the opinion of the trustees to defray the expenses of any illness accident or other emergency or to provide for the proper maintenance support and education of such beneficiary the trustees are authorized to use from time to time so much of the principal of the trust property as the trustees may deem advisable therefor article two of trust provides that trust shall continue in effect unless sooner terminated until twenty-one years after the death of the last to die of the four children of grantor and the grandchildren of grantor living at the date of the trust agreement article two of trust further provides that in the event of the death b without children living any undistributed portion of the trust property shall be divided equally among and added to the other three trusts established by grantor on the same day trust was established failing all such takers the said undistributed portion shall be transferred delivered and paid over to such charitable_organization or organizations as the trustees shall select sec_1361 of the code provides that the term s_corporation means with respect to any taxable_year a small_business_corporation for which an election under sec_1362 is in effect sec_1362 of the code provides that the term small_business_corporation means a domestic_corporation which is not an ineligible_corporation and which does not a have more than shareholders b have as a shareholder a person other than an estate a_trust described in sec_1361 or an organization described in sec_1361 c have a nonresident_alien as a shareholder and d more than one class of stock under sec_1361 of the code an electing_small_business_trust is an eligible shareholder of an s_corporation sec_1361 defines electing_small_business_trust sec_1361 of the code provides that except as provided in sec_1361 the term electing_small_business_trust means any trust if i such trust does not have as a beneficiary any person other than i an individual ii an estate or iii an organization described in paragraph or of sec_170 ii no interest in such trust was acquired by purchase and iii an election under sec_1361 applies to such trust sec_1361 of the code provides that the term electing_small_business_trust shall not include i any qualified_subchapter_s_trust as defined in sec_1361 if an election under sec_1361 applies to any corporation the stock of which is held by such trust ii any trust exempt from tax under subtitle a of chapter and iii any charitable_remainder_annuity_trust or charitable_remainder_unitrust as defined in sec_664 sec_1361 of the code provides that for purposes of sec_1361 the term potential_current_beneficiary means with respect to any period any person who at any time during such period is entitled to or at the discretion of any person may receive a distribution from the principal or income of the trust notice_97_49 1997_2_cb_304 provides that for purposes of sec_1361 the term beneficiary does not include a distributee trust but does include those persons who have a beneficial_interest in the property held by the distributee trust furthermore the notice provides that for purposes of sec_1361 if a distributee trust becomes entitled to or at the discretion of any person may receive a distribution from principal or income of the esbt then the trust will become a potential_current_beneficiary and the s_corporation_election will terminate unless the distributee trust is a_trust described in sec_1361 accordingly based on the representations made and the information provided and the assumption that the interest of any contingent charitable_beneficiary of trust described in sec_170 is so remote as to be negligible and that such contingent charitable beneficiaries are therefore not beneficiaries of trust as described in sec_1361 we conclude that for purposes of sec_1361 the beneficiaries of trust are individuals and are qualified beneficiaries with respect to the power given to the trustees under article one to make certain distributions either directly to or indirectly in trust or otherwise for the benefit of the beneficiary concerned this is a power to make a distribution for purposes of sec_1361 however since there are currently no distributee trusts identified or currently in existence the power to distribute to these trusts will be disregarded for purposes of e thus there is no distributee trust that is a potential_current_beneficiary if a distributee trust is identified or otherwise comes into existence in any period then the distributee trust will become a potential_current_beneficiary and the s_corporation_election will terminate unless the distributee trust is a_trust described in sec_1361 furthermore the beneficiary of any such new trust must satisfy the shareholder restrictions of sec_1361 accordingly upon trust making a valid and timely election under sec_1361 trust will satisfy the requirements of sec_1361 except as specifically set forth above no opinion is expressed concerning the federal tax consequences of the facts described above under any other provision of the code this ruling is directed only to the taxpayer who requested it sec_6110 of the code provides that it may not be used or cited as precedent in accordance with the power_of_attorney of file with this office we are forwarding a copy of this letter to trust sincerely yours j thomas hines senior technician reviewer branch office of the assistant chief_counsel passthroughs and special industries enclosures copy of this letter copy for sec_6110 purposes


department of the treasury washington dc third party communication none date of communication not applicable_person to contact -------------------------- id no ---------------- ----------------- telephone number -------------------- refer reply to cc psi b04 plr-141525-15 date date internal_revenue_service number release date index number ------------------------------------------------------ ------------------------------------------ -------------------------------------- re -------------------------- legend decedent spouse date date ------------- ------------------- ------------------ ----------------------- dear ----------- this letter responds to your personal representative’s letter of date requesting an extension of time pursuant to sec_301_9100-3 of the procedure and administration regulations to make the election under sec_2010 of the internal_revenue_code portability election to allow a decedent’s surviving_spouse to take into account that decedent’s deceased spousal unused exclusion dsue amount the facts and representations are as follows decedent died on date survived by spouse date is a date after the effective date of the amendment to sec_2010 which provides for portability of a dsue amount to a surviving_spouse to obtain the benefit of portability of decedent’s dsue amount to spouse decedent’s estate was required to file form_706 united_states estate and generation-skipping_transfer_tax return on or before the date that is nine months after decedent’s date of death or the last day of the period covered by an extension decedent’s form_706 was due on date but the estate did not file a form_706 to make the portability election the estate discovered its failure to elect portability after the due_date for making the election plr-141525-15 it is represented that the value of decedent’s gross_estate is less than the basic exclusion amount in the year of decedent’s death including any taxable_gifts made during her lifetime you request an extension of time pursuant to sec_301_9100-3 to elect portability of decedent’s dsue amount pursuant to sec_2010 law and analysis sec_2001 imposes a tax on the transfer of the taxable_estate of every decedent who is a citizen or resident_of_the_united_states sec_2010 provides that a credit of the applicable credit_amount shall be allowed to the estate of every decedent against the tax imposed by sec_2001 sec_2010 provides that the applicable credit_amount is the amount of the tentative_tax that would be determined under sec_2001 if the amount with respect to which such tentative_tax is to be computed were equal to the applicable_exclusion_amount on date congress amended sec_2010 effective for estates of decedents dying and gifts made after date to allow portability of a decedent’s unused applicable_exclusion_amount between spouses tax relief unemployment insurance reauthorization and job creation act of pub_l_no sec_303 124_stat_3296 sec_2010 provides that the applicable_exclusion_amount is the sum of the basic exclusion amount and in the case of a surviving_spouse the dsue amount sec_2010 generally provides that the basic exclusion amount is dollar_figure to be adjusted for inflation annually after calendar_year sec_2010 defines the dsue amount to mean the lesser_of a the basic exclusion amount or b the excess of -- i the applicable_exclusion_amount of the last deceased spouse of the surviving_spouse over ii the amount with respect to which the tentative_tax is determined under sec_2001 on the estate of such deceased spouse sec_2010 provides that a dsue amount may not be taken into account by a surviving_spouse under sec_2010 unless the executor of the estate of the deceased spouse files an estate_tax_return on which such amount is computed and makes an election on such return that such amount may be so taken into account the election once made shall be irrevocable no election may be made if such return is filed after the time prescribed by law including extensions for filing such return plr-141525-15 sec_2010 provides that the secretary shall prescribe regulations as may be necessary or appropriate to implement sec_2010 sec_20_2010-2t a of the estate_tax regulations as in effect on date provides that to allow a decedent’s surviving_spouse to take into account that decedent’s dsue amount the executor of the decedent’s estate must elect portability of the dsue amount on a timely-filed form_706 under sec_20_2010-2t a the due_date of an estate_tax_return required to elect portability is nine months after the decedent’s date of death or the last day of the period covered by an extension if an extension of time for filing has been granted under sec_20_2010-2t a the portability election is made by timely filing a complete and properly prepared estate_tax_return unless the executor satisfies the requirements for the election not to apply in sec_20_2010-2t a i sec_301_9100-1 provides that the commissioner may grant a reasonable extension of time under the rules set forth in sec_301_9100-2 and sec_301_9100-3 to make a regulatory election or a statutory election but no more than six months except in the case of taxpayer who is abroad under all subtitles of the code except subtitles e g h and i sec_301_9100-1 provides that the term statutory election means an election whose due_date is prescribed by statute the term regulatory election means an election whose due_date is prescribed by a regulation published in the federal_register or a revenue_ruling revenue_procedure notice or announcement published in the internal_revenue_bulletin sec_301_9100-3 provides the standards the commissioner will use to determine whether to grant an extension of time to make an election whose due_date is prescribed by a regulation and not expressly provided by statute a request for relief under sec_301_9100-3 will be granted when the taxpayer provides evidence to establish to the satisfaction of the commissioner that the taxpayer acted reasonably and in good_faith and that granting relief will not prejudice the interests of the government sec_301_9100-3 provides that a taxpayer is deemed to have acted reasonably and in good_faith if the taxpayer failed to make the election because after exercising reasonable diligence taking into account the taxpayer’s experience and the complexity of the return or issue the taxpayer was unaware of the necessity for the election the due_date for the portability election is prescribed by statute in the case of an estate required to file an estate_tax_return under sec_6018 see sec_2010 sec_6075 and sec_6018 in the case of an estate that is not required to file an estate_tax_return under sec_6018 the due_date is prescribed by regulation see sec_20_2010-2t a plr-141525-15 see also sec_20_2010-2 and revproc_2014_18 2014_7_irb_513 sec_2 accordingly in the latter case a taxpayer may seek an extension of time to elect portability under the provisions of sec_301_9100-3 sec_6018 requires the filing of an estate_tax_return in all cases where the gross_estate exceeds the basic exclusion amount in effect under sec_2010 for the calendar_year which includes the date of death for purposes of this determination under sec_6018 the basic exclusion amount is reduced but not below zero by the sum of -- a the amount of the adjusted_taxable_gifts within the meaning of sec_2001 made by the decedent after date plus b the aggregate amount allowed as a specific exemption under sec_2521 as in effect before its repeal by the tax reform act of with respect to gifts made by the decedent after date it is represented that based on the value of the gross_estate and taking into account any taxable_gifts decedent’s estate is not required to file an estate_tax_return under sec_6018 under these facts the commissioner has discretionary authority under sec_301_9100-3 to grant to decedent’s estate an extension of time to elect portability based on the facts submitted and the representations made we conclude that the requirements of sec_301_9100-3 have been satisfied accordingly we grant an extension of time of days from the date of this letter in which to elect portability under sec_2010 the election should be made by filing a complete and properly-prepared form_706 and a copy of this letter within days from the date of this letter to the cincinnati service_center at the following address internal_revenue_service cincinnati service_center stop cincinnati oh for purposes of electing portability a form_706 filed by decedent’s estate within days from the date of this letter will be considered to be timely filed the rulings contained in this letter are based upon information and representations submitted by the taxpayer and accompanied by a penalty of perjury statement executed by an appropriate party while this office has not verified any of the material submitted in support of the request for rulings it is subject_to verification on examination if it is later determined that based on the value of the gross_estate and taking into account any taxable_gifts decedent’s estate is required to file an estate_tax_return pursuant to sec_6018 the commissioner is without authority under sec_301_9100-3 to grant to decedent’s estate an extension of time to elect portability and the grant of the extension referred to in this letter is deemed null and void this ruling is directed only to the taxpayer requesting it sec_6110 provides that it may not be used or cited as precedent plr-141525-15 in accordance with the power_of_attorney on file with this office a copy of this letter is being sent to your authorized representative sincerely associate chief_counsel passthroughs special industries by lorraine e gardner lorraine e gardner senior counsel branch passthroughs special industries enclosures copy of this letter copy for sec_6110 purposes cc


internal_revenue_service department of the treasury index number washington dc number release date person to contact telephone number refer reply to cc dom p si 1-plr- date date legend x y date date date state a b this responds to a letter dated date submitted on behalf of x requesting a ruling under sec_1362 of the internal_revenue_code facts the information submitted discloses that x is a corporation organized under the laws of state on date on date a and b transferred their shares in x to y an ineligible shareholder x’s s_corporation_election terminated effective date when x discovered that y was an ineligible shareholder they submitted this request for a ruling x represents that the stock held by y was distributed back to a and b on date further x represents that during the termination period it has timely and consistently filed its tax returns consistent with its treatment as an s_corporation x and each person who was a shareholder of x during the termination period plr- agree to make the adjustments consistent with x’s treatment as an s_corporation that are required by the secretary with respect to the termination period in addition x represents that a and b have and shall continue to report their pro_rata share of x’s items of income loss deduction and credit law and analysis sec_1361 defines an s_corporation as a small_business_corporation for which an election under sec_1362 is in effect sec_1361 defines small_business_corporation as a domestic_corporation that is not an ineligible_corporation and that does not a have more than shareholders b have as a shareholder a person other than an estate other than a_trust described in sec_1361 and other than an organization described in c who is not an individual c have a nonresident_alien as a shareholder and d have more than one class of stock sec_1362 of the code provides that an election to be treated as an s_corporation terminates whenever at any time on or after the first day of the first taxable_year for which the corporation is an s_corporation the corporation ceases to be a small_business_corporation the termination is effective on and after the date the s_corporation ceases to meet the requirements of a small_business_corporation sec_1362 sec_1362 of the code provides that if an election to be treated as an s_corporation was terminated under sec_1362 or the secretary determines that the termination was inadvertent no later than a reasonable period of time after discovery of the event resulting in such termination steps were taken so that the corporation is once more a small_business_corporation and the corporation and each person who was a shareholder of the corporation at any time during the period specified pursuant to this subsection agrees to make the adjustments consistent with the treatment of the corporation as an s_corporation as may be required by the secretary with respect to that period then notwithstanding the terminating event the corporation shall be treated as continuing to be an s_corporation during the period specified by the secretary s rep no 97th cong 2d sess 1982_2_cb_718 in discussing sec_1362 of the code provides in part as follows if the internal_revenue_service determines that a corporation's subchapter_s_election is inadvertently terminated the service can waive the effect of the terminating event for any period if the corporation timely corrects the event and if the corporation and the shareholders agree to be treated as if the election had been in effect for such period the committee intends that the internal_revenue_service be reasonable in granting waivers so that corporations whose subchapter_s eligibility requirements have been inadvertently violated do not suffer the tax plr- consequences of a termination if no tax_avoidance would result from the continued subchapter_s treatment in granting a waiver it is hoped that taxpayers and the government will work out agreements that protect the revenues without undue_hardship to taxpayers it is expected that the waiver may be made retroactive for all years or retroactive for the period in which the corporation again became eligible for subchapter_s treatment depending on the facts conclusions based upon the information submitted and the representations set forth above we conclude that the termination of x’s s_corporation_election was inadvertent within the meaning of sec_1362 pursuant to the provisions of sec_1362 x will be treated as continuing to be an s_corporation from date and thereafter provided that x’s subchapter_s_election is not otherwise terminated under sec_1362 in addition for federal tax purposes a and b will be treated as owning their shares in x during the period from date to date except as specifically set forth above no opinion is expressed or implied concerning the federal tax consequences of the above-described facts under any other provision of the code in particular no opinion is expressed or implied concerning whether x’s s election was valid under sec_1362 this ruling is directed only to the taxpayer that requested it sec_6110 of the code provides that it may not be used or cited as precedent pursuant to the power_of_attorney on file with this office a copy of this letter is being sent to your authorized representative sincerely david r haglund senior technician reviewer branch office of the assistant chief_counsel passthroughs and special industries enclosures copy of this letter copy for sec_6110 purposes


internal_revenue_service number release date index number -------------------------------------------------------- ------------------------ ----------------------------------- re ----------------------------------- department of the treasury washington dc third party communication none date of communication not applicable_person to contact --------------------------- id no --------------- ----------------- telephone number --------------------- refer reply to cc psi b04 plr-120897-16 date date legend decedent spouse date date ---------------------------------------------------- ------------------------- ------------------- ------------------------- dear ---------------- this letter responds to your personal representative’s letter of date requesting an extension of time pursuant to sec_301_9100-3 of the procedure and administration regulations to make the election under sec_2010 of the internal_revenue_code portability election to allow a decedent’s surviving_spouse to take into account that decedent’s deceased spousal unused exclusion dsue amount the facts and representations are as follows decedent died on date survived by spouse date is a date after the effective date of the amendment to sec_2010 which provides for portability of a dsue amount to a surviving_spouse to obtain the benefit of portability of decedent’s dsue amount to spouse decedent’s estate was required to file form_706 united_states estate and generation-skipping_transfer_tax return on or before the date that is nine months after decedent’s date of death or the last day of the period covered by an extension decedent’s form_706 was due on date but the estate did not file a form_706 to make the portability election the estate discovered its failure to elect portability after the due_date for making the election it is represented that the value of decedent’s gross_estate is less than the basic exclusion amount in the year of decedent’s death including any taxable_gifts made during her lifetime plr-120897-16 you request an extension of time pursuant to sec_301_9100-3 to elect portability of decedent’s dsue amount pursuant to sec_2010 law and analysis sec_2001 imposes a tax on the transfer of the taxable_estate of every decedent who is a citizen or resident_of_the_united_states sec_2010 provides that a credit of the applicable credit_amount shall be allowed to the estate of every decedent against the tax imposed by sec_2001 sec_2010 provides that the applicable credit_amount is the amount of the tentative_tax that would be determined under sec_2001 if the amount with respect to which such tentative_tax is to be computed were equal to the applicable_exclusion_amount on date congress amended sec_2010 effective for estates of decedents dying and gifts made after date to allow portability of a decedent’s unused applicable_exclusion_amount between spouses tax relief unemployment insurance reauthorization and job creation act of pub_l_no sec_303 124_stat_3296 sec_2010 provides that the applicable_exclusion_amount is the sum of the basic exclusion amount and in the case of a surviving_spouse the dsue amount sec_2010 generally provides that the basic exclusion amount is dollar_figure to be adjusted for inflation annually after calendar_year sec_2010 defines the dsue amount to mean the lesser_of a the basic exclusion amount or b the excess of -- i the applicable_exclusion_amount of the last deceased spouse of the surviving_spouse over ii the amount with respect to which the tentative_tax is determined under sec_2001 on the estate of such deceased spouse sec_2010 provides that a dsue amount may not be taken into account by a surviving_spouse under sec_2010 unless the executor of the estate of the deceased spouse files an estate_tax_return on which such amount is computed and makes an election on such return that such amount may be so taken into account the election once made shall be irrevocable no election may be made if such return is filed after the time prescribed by law including extensions for filing such return sec_2010 provides that the secretary shall prescribe regulations as may be necessary or appropriate to implement sec_2010 plr-120897-16 sec_20_2010-2t a of the estate_tax regulations as in effect on date provides that to allow a decedent’s surviving_spouse to take into account that decedent’s dsue amount the executor of the decedent’s estate must elect portability of the dsue amount on a timely-filed form_706 under sec_20_2010-2t a the due_date of an estate_tax_return required to elect portability is nine months after the decedent’s date of death or the last day of the period covered by an extension if an extension of time for filing has been granted under sec_20_2010-2t a the portability election is made by timely filing a complete and properly prepared estate_tax_return unless the executor satisfies the requirements for the election not to apply in sec_20_2010-2t a i sec_301_9100-1 provides that the commissioner may grant a reasonable extension of time under the rules set forth in sec_301_9100-2 and sec_301_9100-3 to make a regulatory election or a statutory election but no more than six months except in the case of taxpayer who is abroad under all subtitles of the code except subtitles e g h and i sec_301_9100-1 provides that the term statutory election means an election whose due_date is prescribed by statute the term regulatory election means an election whose due_date is prescribed by a regulation published in the federal_register or a revenue_ruling revenue_procedure notice or announcement published in the internal_revenue_bulletin sec_301_9100-3 provides the standards the commissioner will use to determine whether to grant an extension of time to make an election whose due_date is prescribed by a regulation and not expressly provided by statute a request for relief under sec_301_9100-3 will be granted when the taxpayer provides evidence to establish to the satisfaction of the commissioner that the taxpayer acted reasonably and in good_faith and that granting relief will not prejudice the interests of the government sec_301_9100-3 provides that a taxpayer is deemed to have acted reasonably and in good_faith if the taxpayer failed to make the election because after exercising reasonable diligence taking into account the taxpayer’s experience and the complexity of the return or issue the taxpayer was unaware of the necessity for the election the due_date for the portability election is prescribed by statute in the case of an estate required to file an estate_tax_return under sec_6018 see sec_2010 sec_6075 and sec_6018 in the case of an estate that is not required to file an estate_tax_return under sec_6018 the due_date is prescribed by regulation see sec_20_2010-2t a see also sec_20_2010-2 and revproc_2014_18 2014_7_irb_513 sec_2 accordingly in the latter case a taxpayer may seek an extension of time to elect portability under the provisions of sec_301_9100-3 plr-120897-16 sec_6018 requires the filing of an estate_tax_return in all cases where the gross_estate exceeds the basic exclusion amount in effect under sec_2010 for the calendar_year which includes the date of death for purposes of this determination under sec_6018 the basic exclusion amount is reduced but not below zero by the sum of -- a the amount of the adjusted_taxable_gifts within the meaning of sec_2001 made by the decedent after date plus b the aggregate amount allowed as a specific exemption under sec_2521 as in effect before its repeal by the tax reform act of with respect to gifts made by the decedent after date it is represented that based on the value of the gross_estate and taking into account any taxable_gifts decedent’s estate is not required to file an estate_tax_return under sec_6018 under these facts the commissioner has discretionary authority under sec_301_9100-3 to grant to decedent’s estate an extension of time to elect portability based on the facts submitted and the representations made we conclude that the requirements of sec_301_9100-3 have been satisfied accordingly we grant an extension of time of days from the date of this letter in which to elect portability under sec_2010 the election should be made by filing a complete and properly-prepared form_706 and a copy of this letter within days from the date of this letter to the cincinnati service_center at the following address internal_revenue_service cincinnati service_center stop cincinnati oh for purposes of electing portability a form_706 filed by decedent’s estate within days from the date of this letter will be considered to be timely filed the rulings contained in this letter are based upon information and representations submitted by the taxpayer and accompanied by a penalty of perjury statement executed by an appropriate party while this office has not verified any of the material submitted in support of the request for rulings it is subject_to verification on examination if it is later determined that based on the value of the gross_estate and taking into account any taxable_gifts decedent’s estate is required to file an estate_tax_return pursuant to sec_6018 the commissioner is without authority under sec_301_9100-3 to grant to decedent’s estate an extension of time to elect portability and the grant of the extension referred to in this letter is deemed null and void this ruling is directed only to the taxpayer requesting it sec_6110 provides that it may not be used or cited as precedent plr-120897-16 in accordance with the power_of_attorney on file with this office a copy of this letter is being sent to your authorized representative sincerely associate chief_counsel passthroughs special industries by lorraine e gardner lorraine e gardner senior counsel branch office of associate chief_counsel passthroughs special industries enclosures copy of this letter copy for sec_6110 purposes


internal_revenue_service number release date index number - ------------------------------------------------------------ ------------------- ---------------------------------- ---------------------------------------------------------- ---------------------------------------------------- ------------------------------- - department of the treasury washington dc third party communication none date of communication not applicable_person to contact ----------------------- id no ------------- telephone number --------------------- refer reply to cc tege eoeg teb presp-149283-06 date date dear ----------- this letter is in response to your application_for an allocation of authority to issue dollar_figure------- ----------------- in clean renewable energy bonds crebs under sec_54 of the internal_revenue_code the code pursuant to sec_54 of the internal_revenue_code the code and notice_2005_98 2005_52_irb_1211 and after review of your application submitted on date including supplements thereto we have determined that the projects described in appendix a attached hereto are qualified for purposes of sec_54 and will be owned by one or more qualified borrowers we allocate authority to ----------------------------------- --------------------------------------- the issuer a qualified issuer under sec_54 to issue up to dollar_figure--------------- of clean renewable energy bonds crebs bonds issued pursuant to this allocation must be designated by the issuer as bonds for purposes of sec_54 for the projects described in appendix a up to the amount allocated for each project described in appendix a bonds so designated must be issued on or before date please be aware that in order for bonds to be crebs the applicable_requirements of the code including without limitation sec_54 notice_2005_98 and notice_2006_7 2006_10_irb_559 must be met please note that creb proceeds may be used to reimburse capital expenditures paid_by qualified borrowers for qualified projects only if the provisions of sec_54 are met sec_54 of the code imposes a limitation of dollar_figure on the amount of crebs which may be issued to finance qualified projects the limitation sec_54 provides that the limitation is to be allocated by the secretary of treasury in such manner as the secretary deems appropriate except that no more than presp-149283-06 dollar_figure of the limitation may be allocated to finance qualified projects of qualified borrowers which are governmental bodies section of notice_2005_98 2005_52_irb_1211 provides that the limitation will be allocated among qualified projects for which a share of such limitation has been requested beginning with the project s requesting the smallest share in dollar amount and continuing with the project s requesting the next-smallest share until the total limitation has been exhausted however in the event that dollar_figure has been allocated to qualified projects of qualified borrowers that are governmental bodies the remaining shares of the limitation will be allocated under the methodology described in the previous sentence only to qualified projects of qualified borrowers that are not governmental bodies for purposes of allocating the limitation among projects all qualified projects located at the same site and owned by the same qualified_borrower are treated as a single project and each project is treated as requesting a single allocation an allocation of shares of the limitation cannot be made with respect to the project owned by the borrower listed in appendix b because such borrower is a governmental body and dollar_figure has already been allocated to applications requesting a smaller share of the limitation to finance qualified projects owned by qualified borrowers that are governmental bodies we appreciate your submission of the application_for our consideration and encourage you to continue to pursue your plans for constructing clean renewable energy projects if you have any questions with respect to this allocation please contact --------------------- ------------------------------------------------------------------------------------------------------------------- - ---------or -----------------------------of the office of division counsel associate chief_counsel tax-exempt and government entities on --------------------- not a toll-free call except as expressly provided herein no opinion is expressed or implied concerning the tax consequences of any aspect of any transaction or item discussed or referenced in this letter for purposes of the renewable_electricity_production_credit under sec_45 of the code no inference may be drawn from this allocation that any project listed in the appendices attached hereto is a qualified_facility or that electricity to be produced at such project s is electricity from a qualified_energy resource at a qualified_facility within the meaning of sec_45 this determination is directed only to the applicant named above sec_6110 of the code provides that it may not be used or cited as precedent a copy of this letter must be attached to any form 8038-g information_return for tax- exempt governmental obligations filed for bonds issued pursuant to this allocation presp-149283-06 the allocation contained in this letter is based upon information and representations submitted by the applicant for the creb allocation and accompanied by a penalty of perjury statement executed by an appropriate party while this office has not verified any of the material submitted in support of the application_for an allocation it is subject_to verification on examination sincerely assistant chief_counsel exempt_organizations employment_tax government entities tax exempt government entities by timothy l jones senior counsel tax-exempt_bonds branch presp-149283-06 appendix a borrower name ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- project type solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility ----------------------------- ----------------------------- ------------------- solar_energy_facility ----------------------------- ----------------------------- ------------------- solar_energy_facility ----------------------------- ----------------------------- ------------------- solar_energy_facility ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility project location ------------------------------------------ ----------------------------------------- ------------------------------------------ ------------------------------------------ ---------------------------------------- ------------------------------------------ ----------------------------------------- ------------------------------------------ ------------------------------------------ -------- ------------------------------------------ ------------------------------------------ ------------------------------------------ ------ ------------------------------------------ ------------------------------------------ ----------- ------------------------------------------ ------------------------------------------ ------------------ ------------------------------------------ ----------------------------------------- ------------------------------------------ - ------------------------------------------ ----------------------- ------------------------------------------ ------------------------------------ amount allocated ----------- ----------- ----------- ----------- ----------- ----------- ------------- ------------- ------------- ------------- ------------- presp-149283-06 ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility ------------------------------------------ ------------------------------------------ ------------------ -------------------------------------- ------------------------------------------ -------- ------------------------------------------ ---------------------------- ------------------------------------------ ----------- ------------------------------------------ - ----------------------------------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- ----------------------------------------- ------------- ------------------------------------------ ------------- ------------------------------------------ ----------- ------------------------------------------ ------ ------------------------------------------ --------- ------------------------------------------ ------------------------------------------ ------------ ------------- ------------- ------------- ------------- presp-149283-06 ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- -------------------- ------------------------------------------ ------- ------------------------------------------ ------------- ------------- ------------------------------------------ -- ------------------------------------------ - ------------------------------------------ ------------------------ ------------------------------------------ ---------------- ----------------------------------------- ------------------------------------------ ----- ------------------------------------------ -------------------------- ------------------------------------------ ------------------- ------------------------------------------ --------- ------------------------------------------ -------- ------------------------------------------ -------------------- ------------------------------------------ ----- ------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- --------------- solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility presp-149283-06 ----------------------------- ----------------------------- -------------------- ----------------------------- ----------------------------- -------------------- ----------------------------- ----------------------------- -------------------- solar_energy_facility solar_energy_facility solar_energy_facility ----------------------------- ----------------------------- -------------------- solar_energy_facility ----------------------------- ----------------------------- -------------------- ----------------------------- ----------------------------- -------------------- ----------------------------- ----------------------------- -------------------- ----------------------------- ----------------------------- -------------------- ----------------------------- ----------------------------- -------------------- ----------------------------- ----------------------------- -------------------- ----------------------------- ----------------------------- -------------------- ----------------------------- ----------------------------- -------------------- ----------------------------- ----------------------------- ------------------- solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility ------------------------------------------ ------------------ --------------------------------- --------------- --------------- ------------------------------------------ ------------------------------------------ ---------- ------------------------------------------ ------------------------------------------ ---- ------------------------------------------ ---------- -------------------------------- ------------------------------------------ -- ------------------------------------------ ------ ------------------------------------------ ------------------------------------------ ------- ------------------------------------------ -------- ------------------------------------------ ------------------ ------------------------------------------ -------------------- ------------------------------------------ ------- --------------- --------------- --------------- --------------- --------------- --------------- --------------- --------------- --------------- --------------- ------------- presp-149283-06 ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility ----------------------------- ----------------------------- ------------------- solar_energy_facility ------------------------------------------ --------------- ----------------------------------------- ------------------------------------------ ----------------------- ------------------------------------------ ---------- ------------------------------------------ ----------------------------------------- ------------------------------------------ --------------- ------------------------------------------ ------------------ ------------------------------------------ -------------------------- ----------------------------------------- ------------------------------------------ ----- ------------------------------------------ ----------- ------------------------------------------ --------- ------------------------------------------ ------------------------------------------ ------ ------------------------------------------ ---------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- presp-149283-06 ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- --------------------------------- ------------------------------------------ -------------- ------------------------------------------ -------------- ------------------------------------------ ----------- ------------------------------------------ ---------- ------------------------------------------ --------- ------------------------------------------ ---------------- ------------------------------------ ------------------------------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- ------------------------------------- ------------- ---------------------------------- ------------- ------------------------------------------ ------- ----------------------------------------- ------------- ------------- ------------------------------------- ------------- solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility presp-149283-06 ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- ------------------- ----------------------------- ----------------------------- --------------------- ----------------------------- ----------------------------- --------------------- ----------------------------- ----------------------------- --------------------- ----------------------------- ----------------------------- --------------------- ----------------------------- ----------------------------- --------------------- ----------------------------- ----------------------------- --------------------- ----------------------------- ----------------------------- --------------- ------------------------------------------ -------------- ------------------------------------------ ------------- ------------------------------------------ - ------------------------------------------ -- ------------------------------------------ -------- ------------------------------------------ -------------- ------------------------------------------ ------------------------------------------ ------------------------------------------ -- ------------------------------------------ ------------------------ ------------------------------------------ ------------ ------------------------------------------ ---- ---------------------------------------- ------------------------------------------ ---------------------- ------------------------------------------ -------- ------------------------------------------ ---------- ------------- ------------- ------------- ------------- ------------- ------------- ------------- --------------- --------------- --------------- --------------- --------------- --------------- --------------- solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility solar_energy_facility presp-149283-06 total borrower name --------------------------------- --------------------------------- ------------------- ---------------------------------- appendix b ---------------- project type project location solar_energy_facility -------------------------------- ----------------------- amount requested --------------- ------------------------------------------------ ------------------------------------------------- -------------------------- -------------------------------------------- ---------------------------