For example, if a taxpayer discovers that an affiliate was inadvertently undercharged for services rendered or property used in one tax year but subsequently invoices the affiliate in a later year, that should be considered a factor in determining
that the taxpayer acted with reasonable cause and in good faith-even if the IRS determines on examination that the adjustment should have been made during the earlier year.
This involves determining
whether significant changes since the prior year have been properly accounted for and disclosed.
the structure of the ligand, receptor and the complex between the two is key.
No other guidance: Other than the two examples described above, the regulations do not provide detailed guidance for determining
how to amortize debt issuance costs using a constant yield method.
The Board took into account a number of factors in determining
that the Canadian price could not be used as a comparable to the subject transaction.
7 CRITERIA FOR DETERMINING
WHETHER COLLATERAL FOR A LOAN HAS BEEN IN-SUBSTANCE FORECLOSED
280C's wage-expense limit in determining
AMTI, despite that fact that the wage credit on which the limit was based could not reduce liability below TMT.
4682-3T(b)(2)(ii), in determining
if the ODC weight of a product is de minimis, it is necessary to calculate the "adjusted tax," which means the tax that would be imposed under section 4681 on the ODCs used as materials in the manufacture of such products if such ODCs were sold in the United States and the base tax amount were $1.
The most important consideration in determining
the extent of the assurance obtained from an analytical procedure is the precision of the expectation.
The two logical possibilities for determining
the refund date are the (1) refund check's date and (2) the date on which the refund is "scheduled," within the meaning of Sec.
Relying on case law, the court created a four-factor test to determine whether the component part or the larger item of property is the appropriate "unit of property" in determining
whether repair costs are deductible under Sec.
In Custom Chrome, the Ninth Circuit stated that,"[t]he problem in valuing the warrants stems from the combination of the general speculative nature of options aid the related difficulty of determining
precisely what effect options granted for OID have on a core loan transaction.
The rules for determining
whether this exemption applies vary tremendously from state to state; many states' rules provide that if the equipment has a dual use, with only one use qualifying as manufacturing, then tax applies to the extent the equipment performs nonmanufacturing tasks.
448-2T(e)(2) replaced the methods permitted under the original temporary regulations in determining
which amounts a taxpayer is not required to accrue under Sec.
The IRS specified the losses from the sale or exchange of assets that will not have to be taken into account in determining
whether a transaction is reportable under the tax shelter disclosure and advisor-list-maintenance rules.