INCOME TAX

Rev. Rul. 2003–18, page 467. Section 355. This ruling discusses whether the acquisition by D, a brand X automobile dealer, of a brand Y automobile dealership constitutes an expansion of the brand X business or an acquisition of a new or different business under section 1.355– 3(b)(3)(ii) of the regulations. Rev. Rul. 57–190 obsoleted.

Rev. Rul. 2003–19, page 468. Insurance demutualization. This ruling provides guidance as to the tax consequences that occur when, as described in the facts set forth in this ruling, a mutual insurance company converts to a stock insurance company.

Rev. Rul. 2003–20, page 465. New markets tax credit. This ruling holds that, for purposes of determining the new markets tax credit under the facts of the ruling, the amount of the qualified equity investment made by a limited liability company (LLC) classified as a partnership includes cash from a nonrecourse loan to the LLC that the LLC invests as equity in a qualified community development entity.

T.D. 9032, page 471 Final regulations provide guidance with respect to an election under section 645 of the Code to have certain revocable trusts be treated and taxed as part of an estate. These regulations also provide reporting rules for a trust that is treated as owned by the grantor, or another person under provisions of the Code for the taxable year ending with the death of the grantor or other person. Notice 2001–26 and Rev. Proc. 98–13 obsoleted.

Findings Lists begin on page ii.