HIGHLIGHTS OF THIS ISSUE

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

Rev. Rul. 2007–51, page 573. Limitations on setoff under sections 6402 and 6411. This ruling holds that the Service may credit an overpayment against unassessed internal revenue tax liabilities that have been determined in a statutory notice of deficiency sent to the taxpayer. It further holds that under section 6411(b) of the Code, the Service may credit a decrease in tax resulting from a tentative carryback adjustment against unassessed liabilities determined in a statutory notice of deficiency. Rev. Rul. 54–378 clarified.

Rev. Rul. 2007–52, page 575. Definition of a liability under section 6402(a) and 6411(b) . This ruling holds that the Service has the right under section 6402 of the Code to credit an overpayment against internal revenue liabilities for which no assessment has been made, or statutory notice of deficiency issued, when the liabilities are identified in a proof of claim filing in a bankruptcy case. Similarly, the ruling holds that the Service has the right under section 6411(b) to credit a decrease in tax resulting from a tentative carryback adjustment against internal revenue tax liabilities for which no assessment has been made, or statutory notice of deficiency issued, when the liabilities are identified in a proof of claim filed in a bankruptcy case.

Rev. Rul. 2007–53, page 577. Revocation of Rev. Rul.; tentative allowance. The IRS has determined that Rev. Rul. 78–369 is inconsistent with the regulations under section 6411 of the Code. Rev. Rul. 78–369 revoked.

Announcements of Disbarments and Suspensions begin on page 596. Finding Lists begin on page ii.