rr-07-14.pdf

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# Part I

Section 7805 .- Rules and Regulations

26 CFR 301.7805-1: Rules and regulations.

Rev. Rul. 2007-14

The Internal Revenue Service is continuing its program of reviewing guidance
(including revenue rulings, revenue procedures, notices, and actions relating to
decisions of the Tax Court) published in the Internal Revenue Bulletin to identify items
that are obsolete because (1) the applicable statutory provisions have been changed or
repealed; (2) the matter is specifically covered by statute, regulations, or subsequent
published position; or (3) the facts on which the position is based no longer occur or are
not sufficiently described to permit clear application of the current statute and
regulations.

The following revenue ruling is partially obsolete. Rev. Rul. 54-19, 1954-1 C.B.
179, is obsolete with respect to the income tax conclusion, but not with respect to the
estate tax conclusion.

In addition, the rulings listed below are obsolete.

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Ruling No.

C.B. Citation

Rev. Rul. 55-132

1955-1 C.B. 213

Rev. Rul. 56-462

1956-2 C.B. 20

Rev. Rul. 56-518

1956-2 C.B. 25

Rev. Rul. 57-505

1957-2 C.B. 50

Rev. Rul. 58-370

1958-2 C.B. 14

Rev. Rul. 58-500

1958-2 C.B. 21

Rev. Rul. 69-212

1969-1 C.B. 34

Rev. Rul. 71-477

1971-2 C.B. 479

Furthermore, in light of the amendments to § 104(a)(2) of the Internal Revenue
Code under § 1605 of the Small Business Job Protection Act of 1996, Pub. L. No. 104-
188, 110 Stat. 1838 (1996), certain acquiescences to decisions are obsolete. These
amendments make clear that Congress intended "that the exclusion from gross income
[under § 104(a)(2)] only applies to damages received on account of a personal physical
injury or physical sickness", and thus damages received on account of personal
nonphysical injuries or nonphysical sickness generally would be required to be included
in gross income. H.R. Conf. Rep. No. 737, 104th Cong., 2d Sess. 301 (1996), 1996-3
C.B. 1041. Consequently, acquiescences to the following decisions are withdrawn:
Hawkins v. Commissioner, 6 B.T.A. 1023 (1927), acq., VII-1 C.B. 14 (1928).
McDonald v. Commissioner, 9 B.T.A. 1340 (1928), acq., VII-2 C.B. 26 (1928).

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# DRAFTING INFORMATION

The principal author of this revenue ruling is Christina M. Glendening of the
Office of Associate Chief Counsel (Income Tax and Accounting). For further
information regarding this revenue ruling, contact Ms. Glendening at (202) 622-4920
(not a toll-free call).