Bulletin No. 2003-29 July 21, 2003

Rev. Rul. 2003–79, page 80. Section 355 reverse Morris trust. The acquisition by an unrelated corporation of all the assets of a newly formed controlled corporation following distribution of the controlled corporationÊs stock under section 355 of the Code will satisfy the "substantially all" requirement of section 368(a)(1)(C) even though the acquired assets represent only half of the assets held by the distributing corporation before it formed the controlled corporation.

Rev. Rul. 2003–80, page 83. Statute of limitations, bankruptcy. This ruling explains the effect of a bankruptcy on the running of the statute of limitations on assessment set forth in section 6501 of the Code. The ruling illustrates that when the IRS issues a Notice of Deficiency less than 90 days before the taxpayer files a bankruptcy petition, the same day the taxpayer files a bankruptcy petition, or after the taxpayer files a bankruptcy petition, and before the termination of the automatic stay imposed by the bankruptcy, the assessment period is suspended not only by the 60-day period provided by section 6503(a), but also by the additional 60-day period provided by section 6213(f).

Rev. Rul. 2003–87, page 82. LIFO; price indexes; department stores. The May 2003 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, May 31, 2003.

Announcement 2003–47, page 124. This announcement notifies the public of changes to Form 8873, Extraterritorial Income Exclusion, and its Instructions. This announcement also provides the reasons for these changes.

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