The full text on this page is automatically extracted from the file linked above and may contain errors and inconsistencies.
X-9833 Reg. f-10 INTERPRETATION OF LAW OR REGULATION (Copies to be sent to all Federal reserve banks) February £5, 1957 Relet February 11, 1957, transmitting copy of letter from Company, , . from which it ap- pears that such company desires to know whether cash, accounts receivable, or notes receivable may be considered readily marketable assets acquired in compliance with section 5144 of the Revised Statutes for purpose of possible claim for tax credit under section 26(d) of Revenue Act of 1956. Board feels that it should rule upon questions of this nature only in making certifications under section 26(d) with respect to claims made for tax credit in tax returns and upon basis of all facts involved in particular claims. It is assumed that Company has in mind that even though particular kinds of assets might constitute readily marketable assets within meaning of section 5144, the question whether a holding company affiliate is entitled to a tax credit for any increase in amount of such assets during a taxable year involves other questions, including whether such increase resulted from devotion of earnings or profits to acquisition of such assets. It is suggested that you call attention of holding company af- filiate to desirebility of furnishing full information upon which any such claim is predicated as provided in regulation of Bureau of Internal Revenue inclosed with Board's letter X-9757. (Signed) Chester Morrill MORRILL