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IRB 2007-14

Table of Contents
(Dated April 2, 2007)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2007-14. Click on an entry to view the entry. Items shown under "Highlights of This Issue" open summaries of each IRB-referenced document only. Scroll to Parts I, II, etc. to view the full text versions of each IRB-referenced document. Use the "Keyword Search" option of TouchTax to search the full text of all Internal Revenue Bulletins, including this IRB.

View the original PDF version of this Internal Revenue Bulletin

Highlights of This Issue

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

Frivolous tax returns; wages not taxable income. This ruling discusses and refutes the frivolous position taken by some taxpayers that wages are not taxable income.

Frivolous tax returns; voluntary compliance. This ruling discusses and refutes the frivolous position taken by some taxpayers that complying with the internal revenue laws is purely voluntary and that taxpayers are not legally required to file federal tax returns or pay federal tax because the filing of a tax return or the payment of tax is a matter of choice.

Frivolous tax returns; summary record of assessment. This ruling discusses and refutes the frivolous position taken by some taxpayers that before the IRS may collect overdue taxes, the IRS must provide taxpayers with a summary record of assessment made on a Form 23C, Assessment Certificate-Summary Record of Assessments, or on another particular form. These taxpayers claim that if a Form 23C is not provided, the assessment is invalid and the IRS may not collect any taxes due.

Frivolous tax returns; citizens of a state. This ruling discusses and refutes the frivolous position taken by some taxpayers that they are not subject to federal income tax, or that their income is excluded from taxation, because either (1) they claim to have rejected or renounced United States citizenship and are citizens exclusively of a state (sometimes characterized as a “natural-born citizen” of a “sovereign state”), or (2) they are not persons as identified by the Internal Revenue Code.

Final regulations under section 168 of the Code relate to the depreciation of property subject to the accelerated cost recovery system (MACRS property). The regulations provide guidance on how to depreciate MACRS property acquired in a like-kind exchange under section 1031 or as a result of an involuntary conversion under section 1033 when both the acquired and relinquished property are subject to MACRS in the hands of the acquiring taxpayer.

This notice solicits applications for allocation of the available volume cap for clean renewable energy bonds (CREBs) under section 54 of the Code. The notice also provides guidance on the CREB program requirements, volume cap allocation method, and certain aspects of applicable law regarding CREBs. Notice 2005-98 modified and superseded.

Request for comments and interim guidance regarding allocation of costs under the simplified methods of accounting under section 263A. This notice invites public comment on changes to the simplified production method under regulations section 1.263A-2(b) and the simplified resale method under regulations section 1.263A-3(d). Pending the issuance of additional published guidance, the Service will not challenge the inclusion of negative amounts in computing additional costs under section 263A of the Code or the permissibility of aggregate negative additional section 263A costs.

This notice lists positions identified as frivolous for purposes of section 6702(c) of the Code.

EMPLOYEE PLANS

Deductibility; contributions; sections 801 and 803 of the Pension Protection Act of 2006. This notice addresses, in question and answer format, the deductibility of certain contributions to qualified defined benefit pension plans under section 404(a)(1) of the Code and the deductibility of certain contributions to a combination of plans under section 404(a)(7).

EXEMPT ORGANIZATIONS

This notice lists positions identified as frivolous for purposes of section 6702(c) of the Code.

This procedure sets forth the elements of a safe harbor under section 527(1) of the Code for waiver of amounts due for failure to comply with certain reporting requirements due to reasonable cause but not willful neglect.

ESTATE TAX

Frivolous tax returns; voluntary compliance. This ruling discusses and refutes the frivolous position taken by some taxpayers that complying with the internal revenue laws is purely voluntary and that taxpayers are not legally required to file federal tax returns or pay federal tax because the filing of a tax return or the payment of tax is a matter of choice.

This notice lists positions identified as frivolous for purposes of section 6702(c) of the Code.

GIFT TAX

Frivolous tax returns; voluntary compliance. This ruling discusses and refutes the frivolous position taken by some taxpayers that complying with the internal revenue laws is purely voluntary and that taxpayers are not legally required to file federal tax returns or pay federal tax because the filing of a tax return or the payment of tax is a matter of choice.

This notice lists positions identified as frivolous for purposes of section 6702(c) of the Code.

EMPLOYMENT TAX

Frivolous tax returns; wages not taxable income. This ruling discusses and refutes the frivolous position taken by some taxpayers that wages are not taxable income.

Frivolous tax returns; voluntary compliance. This ruling discusses and refutes the frivolous position taken by some taxpayers that complying with the internal revenue laws is purely voluntary and that taxpayers are not legally required to file federal tax returns or pay federal tax because the filing of a tax return or the payment of tax is a matter of choice.

Frivolous tax returns; citizens of a state. This ruling discusses and refutes the frivolous position taken by some taxpayers that they are not subject to federal income tax, or that their income is excluded from taxation, because either (1) they claim to have rejected or renounced United States citizenship and are citizens exclusively of a state (sometimes characterized as a “natural-born citizen” of a “sovereign state”), or (2) they are not persons as identified by the Internal Revenue Code.

This notice lists positions identified as frivolous for purposes of section 6702(c) of the Code.

SELF-EMPLOYMENT TAX

Frivolous tax returns; voluntary compliance. This ruling discusses and refutes the frivolous position taken by some taxpayers that complying with the internal revenue laws is purely voluntary and that taxpayers are not legally required to file federal tax returns or pay federal tax because the filing of a tax return or the payment of tax is a matter of choice.

This notice lists positions identified as frivolous for purposes of section 6702(c) of the Code.

EXCISE TAX

Frivolous tax returns; voluntary compliance. This ruling discusses and refutes the frivolous position taken by some taxpayers that complying with the internal revenue laws is purely voluntary and that taxpayers are not legally required to file federal tax returns or pay federal tax because the filing of a tax return or the payment of tax is a matter of choice.

This notice lists positions identified as frivolous for purposes of section 6702(c) of the Code.

ADMINISTRATIVE

Frivolous tax returns; wages not taxable income. This ruling discusses and refutes the frivolous position taken by some taxpayers that wages are not taxable income.

Frivolous tax returns; voluntary compliance. This ruling discusses and refutes the frivolous position taken by some taxpayers that complying with the internal revenue laws is purely voluntary and that taxpayers are not legally required to file federal tax returns or pay federal tax because the filing of a tax return or the payment of tax is a matter of choice.

Frivolous tax returns; summary record of assessment. This ruling discusses and refutes the frivolous position taken by some taxpayers that before the IRS may collect overdue taxes, the IRS must provide taxpayers with a summary record of assessment made on a Form 23C, Assessment Certificate-Summary Record of Assessments, or on another particular form. These taxpayers claim that if a Form 23C is not provided, the assessment is invalid and the IRS may not collect any taxes due.

Frivolous tax returns; citizens of a state. This ruling discusses and refutes the frivolous position taken by some taxpayers that they are not subject to federal income tax, or that their income is excluded from taxation, because either (1) they claim to have rejected or renounced United States citizenship and are citizens exclusively of a state (sometimes characterized as a “natural-born citizen” of a “sovereign state”), or (2) they are not persons as identified by the Internal Revenue Code.

This notice solicits applications for allocation of the available volume cap for clean renewable energy bonds (CREBs) under section 54 of the Code. The notice also provides guidance on the CREB program requirements, volume cap allocation method, and certain aspects of applicable law regarding CREBs. Notice 2005-98 modified and superseded.

This notice lists positions identified as frivolous for purposes of section 6702(c) of the Code.



The Internal Revenue Bulletin is produced and published by the Internal Revenue Service and contains IRS pronouncements affecting tax analysis under the Code and the Regulations, including but not limited to Revenue Procedures, Revenue Rulings, Notices and Announcements. Access the IRS site at https://www.irs.gov/help/irsgov-accessibility for information concerning accessibility of IRS materials. While every effort has been made to ensure that the IRB database files available through the TouchTax application are accurate, those using TouchTax for legal research should verify their results against the printed versions of the IRBs available from the IRS.