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IRC Section 7873 - PLR

Private Letter Rulings - IRC Section 7873

Issue

PLR Number

1.Whether funds attributable to the Settlement Agreement are, pursuant to Code Section 7873, income derived from a fishing rights-related activity of X, and exempt from federal income tax.

2.Whether a per capita distribution of funds attributable to the Agreement to member of X, will not be "wages" subject to FICA and FUTA taxes upon distribution because such payments are pursuant to Section 7873, income derived from a fishing rights-related activity of X, and exempt from federal employment taxes.

3.Whether because the funds attributable to the Agreement and distributed as per capita payments to X members are exempt from the imposition of federal income and employment taxes pursuant to Code Section 7873, X is not subject to Code Section 6041 reporting requirements with respect to the amounts distributed.

PLR -200511006

(PLR-136832-04)

11/23/2004

Page Last Reviewed or Updated: 2013-03-27