1. On September 12, 2010, the IRS issued PLR 2010005369, whi…

1. On September 12, 2010, the IRS issued PLR 2010005369, which addresses a related-party transaction involving bonds. A few years after the PLR was published, the IRS issued regulations that adopted the ruling contained within the PLR. Promethius Corporation, a sophisticated taxpayer with a tax issue similar to the scenario addressed in PLR 20100005369, wishes to cite to it as authority in its discussion with IRS agents. What should Promethius Corporation cite to? 

4. On February 10, 2013, the IRS issued Treas. Reg. § 1.385-…

4. On February 10, 2013, the IRS issued Treas. Reg. § 1.385-1T which provided rules pertaining to the analysis of whether an instrument is debt or equity for federal income tax purposes. X Corporation, a sophisticated taxpayer wishes to rely upon the regulation to support its position that a loan it extended to a related party is debt rather than equity. Can it rely upon the regulation for taxable year 2023?