This case is certainly an indication that field agents are looking deeper into a taxpayer's application of simplified methods when it comes to allocating
uniform capitalization costs.
supportive expenses to a class of gross income narrower than all gross income, a more favorable apportionment may be achieved for FTC limitation purposes.
The regulations contain no examples of allocating
capital gain under a power to adjust.
Presumably, the same methods of allocating
costs between ending inventory and cost of goods sold should be acceptable when allocating
Although various approaches to allocating
tolerable misstatement may be employed, the example shown below assumes a straightforward distribution among financial statement elements.
An excellent basis for allocating
postage is the incremental weight a program or fund-raising contributes to the mailings weight.
First, according to the IRS, not every method of allocating
plan expenses is reasonable and could result in a significant detriment.
The IRS issued final regulations on directly allocating
unrelated party interest expense to interest income from related controlled foreign corporations (CFCs).
Exhibit 4 at left presents a corresponding Schedule C, Part 2, allocating
GST exemption to this transfer.
This lack of conflicting interests weakens the economic reality test's usefulness in allocating
a portion of the purchase price to intangible assets.
The two methods involve allocating
a GST exemption either (1) to the trust on an annual basis equal to each trust contribution or (2) against the trust's fair market value (FMV) at the time of the allocation.
Under these circumstances, there is no factual basis for allocating
two thirds of the total amount paid to B to emotional distress; the allocation does not reflect the economic substance of the settlement, nor the realities of the underlying claim.
2642(g)(1)(B), taxpayers should treat the time for allocating
the GST exemption to lifetime transfers and transfers at death, the time for electing to opt out of the automatic allocation rules, and the time for electing to treat any trust as a GST trust as if not expressly prescribed by statute.
1.752-3 currently provides a three-tiered system for allocating
nonrecourse liabilities, which applies sequentially.
706 varying-interest rule effectively prohibits a partnership from retroactively allocating
a full share of partnership tax items for a partnership tax year to persons who were partners for only a portion of the year.