Field Service Advice

Bulk operations

The IRS has issued Field Attorney Advice that concludes a business cannot deduct contributions of food inventory because it failed to attach properly completed Form 8283 to its tax return and failed to properly value its donations.

In field service advice, the IRS has determined that further factual development is necessary to determine if a company is entitled to deduct the fair market value of contract rights given to a charity.
Full Text:

UILC: 2511.00-00, 2522.02-01, 2035.02-00
Release Date: 6/112001

Date: February 20, 2001

Refer Reply to: CC:PSI:9


In field service advice, the IRS has concluded it needs more information to determine whether taxpayers may deduct a contribution of a portion of their cooperative housing shares and a proprietary lease to rent their cooperative apartment to a public charity. This is...
Can a simple a trust whose governing instrument does not authorize the trustee to make charitable contributions claim a charitable deduction for its distributive share of a charitable contribution made by a partnership, in which the trust is a partner? In field service...
In Field Service Advice 1995-4, released today, the Service advised that a grocery chain could not take a charitable income tax deduction equal to the full retail price of fresh bread for donations of four-day old bread to food banks.
In Field Service Advice 200022005, the IRS recommended rejection of a proposed settlement agreement involving the invasion of a charitable remainder trust to pay the donor's federal tax liability.
In FSA 1999-1174, the National Office of the Service held that an estate tax charitable deduction should be denied because (i) the decedent did not have a primarily charitable intent, but rather intended the estate's residue to pass to a particular entity in all events...
In apparently related FSA's (FSA 1999-1193 and FSA 1999-1172), the Service (i) disallowed an income tax deduction for a payment from the estate's income to an entity which was not a qualified charity, and (ii) held that the estate does not qualify for a charitable...
In an undated Field Service Advice, the IRS holds that a contribution of a facade easement in real property, which does not otherwise qualify as a certified historic structure, qualifies for deduction as an open space easement based on the fact the Gift Deed prohibits...
In FSA 1999-1070, the Service, quoting Hernandez v. Commissioner, 490 U.S. 680 (1989), held that tuition payments to a religious school are not deductible under section 170 of the Code because the Taxpayers received a substantial benefit on account of the payments.
In Field Service Advice 1999-951, the Service held that a wholly- owned subsidiary was not entitled to a charitable contribution deduction for its donation of an option to purchase real property.
In FSA 1999-923, the IRS advised that although a surviving spouse's initial transfer of stock from a qualified terminable interest property ("QTIP") trust to the charitable remainder beneficiary of the QTIP was a non-qualified split interest transfer for gift tax...
In a recently-released 1992 Field Service Advice memorandum, the IRS and case rulings present inconsistent positions for valuing Rule 144 stock at death.
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Define: Field Service Advice

Field Service Advice (FSA) is correspondence from the IRS National Office to a revenue agent for the purpose of confirming a preexisting IRS position to the facts in a particular case. An FSA does not act as a final determination; thus, a revenue agent need not follow it if the taxpayer produces more compelling arguments in support of a contrary position.