Ezel / IRS Rulings / 200151011

TAM 200151011: IRS reversed prior stripped coupon ownership conclusion

Number
200151011
Outcome
Advice
Document type
Technical Advice Memorandum
IRS subject
Tax Treatment of Stripped Bonds
Topics
Income and deductions Property transactions and exchanges Procedure, penalties, and administration
Code sections
§ 1286, § 6110
Ruling dated
September 14, 2001
Publicly released
December 21, 2001
Source
View Official PDF

Apply this to your situation

This page covers IRS technical advice on one taxpayer's case, issued in 2001, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2001
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It answered an IRS office's question about one taxpayer's case on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

The IRS reconsidered an earlier technical advice memorandum about a taxpayer's Program B. The earlier advice had concluded that the taxpayer became the owner of stripped coupons under § 1286(e)(2), using the analysis of Revenue Ruling 91-46. This memorandum reverses that conclusion: the taxpayer did not become the owner of the stripped coupons under that provision. The public release does not describe Program B or explain the reconsideration further.

Ruling snapshot

  • Question: Did the taxpayer become the owner of stripped coupons under § 1286(e)(2) in Program B?
  • Outcome: Advice given: the IRS concluded it did not.
  • Key authorities: IRC § 1286(e)(2); Rev. Rul. 91-46.

Full text (IRS public release)

Number: 200151011
Release Date: 12/21/2001
Index Numbers: 0083.05-00, 0166.01-00, 0167.14-00, 0263.21-00, 1092.09-00, 1221.00-00, 1256.06-01, 1286.00-00, 7805.05-00 Control Number: TAM-148232-01/CC:FIP:2

INTERNAL REVENUE SERVICE
NATIONAL OFFICE
TECHNICAL ADVICE MEMORANDUM

September 14, 2001

LEGEND:

Taxpayer =

Taxpayer’s Address =

Taxpayer’s E.I.N. =

Program B =

On December 13, 1993, a Technical Advice Memorandum (TAM 9410008, hereinafter the "TAM") was issued concerning Taxpayer. We have reconsidered the conclusion of that TAM, with respect to Program B, that Taxpayer became the owner of stripped coupons within the meaning of section 1286(e)(2) of the Internal Revenue Code under the analysis of Rev. Rul. 91-46. As a result of that reconsideration, we have concluded that Taxpayer did not become the owner of stripped coupons under section 1286(e)(2).

A copy of this technical advice memorandum is to be given to Taxpayer. Section 6110(k)(3) of the Code provides that it may not be used or cited as precedent.

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