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SECTION 2. BACKGROUND Section 5 of Rev. Pro. 97 3 lists areas under extensive study in which rulings or determination letters will not be issued until the Service resolves the issue through publication
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The Service determined on April 17, 1994, that certain of the provisions of this notice (including section 12b-2 of the Code) had been violated in the 1984 and 1988 distributions. It also determined that the 1984 distribution had not been made in conformity with the requirements of Section 12b-2 (e.g., that dividends be paid no later than six months after the taxable year in which they are paid), and that the 1985 distribution had not been made in conformity with Section 12b-21 and all regulations thereunder. Section 12b-2 of the Code prohibits distributions made by a trust that have the effect of causing any interest of the beneficiaries in the trust to be converted into taxable income of the trust. Section 12a-21 of the Code requires that a distribution of a specified class of stock to all the beneficiaries of the trust from the plan be made promptly and in compliance with the law. Section 12a-21(b) of the Code applies to the 1982 and 1983 distributions, but only if the trustee, the administrator, or the director of administration of the plan fails to comply with its applicable provisions. This notice also specifies that the trustee, administrator, or director of administration has failed to comply with the requirements of Section 12b-2 of the Code. Consequently, the 1984 and 1988 distributions are now covered by section 355(a)(1) of the Code. As a result of the determination in subsection (b) of this section, the 1984 and 1988 distributions of the trust are taxable within the meaning of Section 12b-2 of the Code. (4) DATE OF TRANSMITTAL The notice concerning the 1984 and 1988 distributions was transmitted on May 13, 1994. (5) IMPLEMENTATION If the plan has any outstanding tax liability on the 1984 and 1988 distributions, then the required tax will be assessed and collected by the Service before the distribution is made and will be paid by the beneficiary. (6) ADDRESS RECEIPTS If any portion of the required tax is not paid at the time the distribution is made, the remainder of the required tax will be due from each recipient of the distribution at the time of receipt.

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Revenue Procedure 53 provides guidelines and instructions for taxpayers on how to request a change in accounting method for federal income tax purposes.
Any taxpayer who wishes to request a change in accounting method for federal income tax purposes is required to file revenue procedure 53.
To fill out revenue procedure 53, taxpayers need to follow the instructions provided in the procedure. This includes providing relevant information about the current accounting method, the proposed method, and the reasons for the change.
The purpose of revenue procedure 53 is to provide a standardized process for taxpayers to request a change in accounting method for federal income tax purposes. It ensures that taxpayers follow proper procedures and provide sufficient information to support their request.
Revenue procedure 53 requires taxpayers to report detailed information about their current accounting method, the proposed method, and the impact of the change on their tax liabilities. This includes providing schedules, calculations, and supporting documents as necessary.
The specific deadline to file revenue procedure 53 in 2023 will depend on the taxpayer's individual circumstances. It is recommended to refer to the latest IRS guidelines or consult with a tax professional for the most accurate and up-to-date information.
The penalties for the late filing of revenue procedure 53 may vary depending on various factors, such as the taxpayer's compliance history and the reasons for the delay. It is important for taxpayers to file the procedure in a timely manner to avoid any potential penalties or consequences. It is advisable to consult with a tax professional or refer to the latest IRS guidelines for specific penalty provisions.
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