Ezel / IRS Rulings / 201013048

CCA 201013048: IRS comments on the status of bonds and depreciation

Number
201013048
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Qualified Small Issue Bond; Qualified Student Loan Bond; Qualified Redevelopment Bond
Topics
Income and deductions
Code sections
§ 144, § 6110
Ruling dated
March 2, 2010
Publicly released
April 2, 2010
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2010, 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 2010
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 is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, 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

Chief Counsel advice addressed the status of certain bonds discussed in a focus-group presentation. The memorandum stated that the issue appeared to involve how a case is handled when the underlying problem is depreciation. It did not provide a detailed analysis or a final ruling in the released text.

Ruling snapshot

  • Question: How should the status of the bonds be understood when the underlying issue involves depreciation?
  • Outcome: Advice given
  • Key authorities: IRC § 144; IRC § 6110(k)(3) not-precedent notice

Full text (IRS public release)

ID: CCA_2010030214293234 Number: 201013048
Release Date: 4/2/2010
Office: ----------------
UILC: 144.00-00

From: ---------------------------
Sent: Tuesday, March 02, 2010 2:29:33 PM
To: ---------------------------------------------------------------
Cc: ------------------
Subject: RE: Focus Group - Case 7221 Presentations

I concur with --------- and ----- regarding the status of the bonds. Sounds like a difference of how the case
is handled when the problem is really depreciation.

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