| 19(1) | File No. 900869 |
| W.C. Bailey | |
| 957-2061 |
June 21, 1990
19(1)
Re: Donation to 24(1)
This will reply to your letter of May 16, 1990 concerning your proposed gift to the 24(1).
You have asked us to rule that the proposed gift of 24(1).
We regret that we cannot give you the assurances you request. It is a question of fact as to whether you are the owner of these materials. The Department is not prepared to rule on questions of fact until the pertinent transaction has been accomplished and thereby becomes a subject with tax implication. We can only suggest that you talk to officials at the District Taxation Office where you file your returns to discuss the information you will need to produce to establish your claim.
Yours sincerely,
E.M. Wheeler For DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch