INCOME TAX

Ct. D. 2079, page 978. Tax assessment; partnership. The Supreme Court holds that the proper assessment against the partnership suffices to extend the statute of limitations to collect the tax in a judicial proceeding from the general partners who are liable for the payment of the partnership’s debts. United States v. Galletti et al.

Rev. Rul. 2004–45, page 971. Health Savings Account (HSA) – interaction with other health arrangements. This ruling addresses the interaction between Health Savings Accounts (HSAs), health flexible spending arrangements (health FSAs), and health reimbursement arrangements (HRAs).

Rev. Rul. 2004–52, page 973. Credit card annual fees. This ruling holds that credit card annual fees are not interest for federal income tax purposes. Moreover, the ruling holds that credit card annual fees are includible in the gross income by the card issuer when they become due and payable by cardholders under the terms of the credit card agreements.

Notice 2004–39, page 982. This notice explains how the changes to section 1(h) of the Code made by the Jobs and Growth Tax Relief Reconciliation Act of 2003 (JGTRRA) apply to capital gain dividends paid (or accounted for as if paid) by regulated investment companies (RICs) and real estate investment trusts (REITs) in taxable years that end on or after May 6, 2003.