Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 78-78

1978-1 C.B. 449

Sec. 7805

IRS Headnote

Obsolete rulings. Additional pre-1953 rulings relating to income and profit taxes are obsoleted.

Full Text

Rev. Rul. 78-78

Rev. Proc. 67-6, 1967-1 C.B. 576, announced a program for the review of rulings published in the Internal Revenue Bulletin before 1953 with the immediate objective of identifying and publishing lists of those rulings that, although not specifically revoked or superseded, are not considered determinative with respect to future transactions.

In accordance with that program and based on a review of rulings relating to income and profits taxes, the rulings listed below are hereby declared obsolete.

     General (or Chief) Counsel's Memorandum (G.C.M.) Ruling Series
G.C.M.
Number                              C.B. Citation
6563                           VIII-2 C.B. 186 (1929)
14839                           XIV-1  C.B.  73 (1935)
     Income Tax (I.T.) Ruling Series
I.T. Number                         C.B. Citation
   3123                            1937-2 C.B. 114
   3936                            1949-1 C.B.  64
   4089                            1952-2 C.B. 142

The purpose in declaring these rulings obsolete is to make it clear to all concerned that the above-listed rulings are not determinative with respect to future transactions. It is not the purpose of this Revenue Ruling to determine the applicability of any of the listed rulings to past transactions.

A further review is being made of other old rulings. Therefore, failure to include any particular ruling in this or previous lists should not be construed as an indication that the ruling necessarily is determinative with respect to future transactions.