SECTION 12. DRAFTING
Internal Revenue Bulletin 2005-2 · 2026-10-03 edition · updated 2026-10-04 · United States
INFORMATION
The principal author of this revenue procedure is Stephen Suetterlein of the Office of Associate Chief Counsel (Tax Exempt and Government Entities). For further information regarding this revenue procedure, contact Mr. Suetterlein at (202) 622–6040 (not a toll-free call).
inappropriate to apply the standards of this revenue procedure to conclude that the individual’s work has become incident to and for the purpose of pursuing a course of study solely because the individual enrolled for this course work. In both of these examples, whether the work is performed incident to and for the purpose of pursuing a course of study must be determined on the basis of all the relevant facts and circumstances.
26 CFR 601.202: Closing agreements. (Also Part I, §§ 446, 482, 7121; 1.446–1, 301.7121–1.)
Rev. Proc. 2005–12
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