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11 <br />03/2000 <br />PLR-116685-99 4 <br />under state law. Section 301.7701-1 (a) (3) of the Procedural and <br />Administrative Regulations. <br />City has made a substantial financial commitment to Trust by <br />providing all of its funding. City retains complete control over <br />Trust because it may amend or terminate Trust at any time. City <br />retains control over the daily operation of Trust by its power to <br />appoint or remove agents who manage daily operation. The Trustee <br />is merely a title holder with no power to manage Trust. <br />CONCLUSION <br />Provided that City is the only person that makes <br />contributions to Trust, and Trust accepts or holds only amounts <br />of money contributed by City, Trust will be an integral part of <br />City, and any income earned on amounts in Trust will not be <br />subject to federal income tax. <br />This ruling is directed only to the. taxpayer that requested <br />it. Section 6110(k)(3) of the Code provides that it may not be <br />used or cited as precedent. <br />Except as specifically provided otherwise, no opinion is <br />expressed on the federal income tax consequences of the <br />transaction described above. <br />In accordance with the terms of a power of attorney on file <br />in this office, a copy of th' letter is being sent to your <br />authorized representative. <br />Sincerely, <br />Assistant Chief Counsel <br />(Financial Institutions & Products) <br />By: William Coppersmith <br />William E. Coppersmith <br />Chief, Branch 2 <br />13 <br />