us-irs-revenue-procedures-rp-05-61•rp-05-61.pdf
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<!-- PageHeader="CASE MIS No .: RP-131823-05" --> # Part III Administrative, Procedural, and Miscellaneous 26 CFR 601.201: Rulings and determination letters (Also: §§ 61, 451 and 1001) Rev. Proc. 2005-61 ## SECTION 1. PURPOSE This revenue procedure amplifies Rev. Proc. 2005-3, 2005-1 I.R.B. 118, which sets forth areas of the Internal Revenue Code in which the Internal Revenue Service will not issue advance rulings or determination letters. SECTION 2. BACKGROUND .01 Section 3 of Rev. Proc. 2005-3 sets forth a list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions & Products), the Associate Chief Counsel (Income Tax & Accounting), the Associate Chief Counsel (Passthroughs & <!-- PageBreak --> Special Industries), the Associate Chief Counsel (Procedure and Administration), and the Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities) relating to issues on which the Internal Revenue Service will not issue letter rulings or determination letters. .02 In Rev. Proc. 2005-62, page [INSERT PAGE NUMBER] this Bulletin, the Service provides a safe harbor with respect to the tax treatment of certain cost recovery transactions by regulated investor owned utility companies. ## SECTION 3. PROCEDURE Rev. Proc. 2005-3 is amplified by adding the following to section 3.01: Sections 61, 451 and 1001. Gross Income Defined; General Rule for Taxable Year of Inclusion; Determination of Amount and Recognition of Gain or Loss. Whether, under authorization by an appropriate State agency to recover certain costs pursuant to State specified cost recovery legislation, any investor-owned utility company realizes income upon: (1) the creation of an intangible property right; (2) the transfer of that intangible property right; or (3) the securitization of the intangible property right. SECTION 4. EFFECT ON OTHER DOCUMENTS Rev. Proc. 2005-3 is amplified. ## SECTION 5. EFFECTIVE DATE This revenue procedure applies to all ruling requests pending or submitted after [INSERT DATE THIS DOCUMENT IS PUBLISHED IN THE INTERNAL REVENUE BULLETIN]. <!-- PageBreak --> # SECTION 6. DRAFTING INFORMATION The principal author of this revenue procedure is Thomas M. Preston of the Office of Associate Chief Counsel (Financial Institutions & Products). For further information regarding this revenue procedure contact Mr. Preston at (202) 622-3970 (not a toll free call).
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