References in periodicals archive ?
It then reviewed the relevant cases, the amendment of Regs.
As the Tax Court is the first court to consider the validity of Regs.
If a taxpayer that is eligible under this notice to participate in this initiative files all required returns for tax years ending in 1996 and all subsequent years for which the applicable deadline set forth in Regs.
Decision: The Tax Court ruled for the taxpayer, noting that Regs.
The taxpayer admitted that he wanted to make the late election to reduce his taxes, and argued that Regs.
It has allowed this exclusion under the final regulations, as long as the taxpayer meets the land safe-harbor rules; see Regs.
If an existing hedging transaction is "recycled" to hedge a different asset or liability, it must be re-identified on the day that it is recycled; see Regs.
parent enters into a new GILA (for the remainder of the original five-year term), in which it agrees to recognize the gain in accordance with Regs.
Accordingly, the IRS's allocation relating to the grant date value fails to meet the arm's-length standard mandated by Regs.
To the extent not already accounted for, the parent should increase its basis in its subsidiary stock for the cash contribution under Regs.
The partners' capital accounts will be maintained in accordance with Regs.
Because the OID under this calculation ($130,000) is more than the de minimis amount of OID for the loan, determined under Regs.
taxpayer can elect an entity's tax classification under the "check-the-box" regulations in Regs.
The amount of money or other property is limited, however, by the COI requirement under Regs.
The proposed regulations defined "tax book value" simply as "adjusted basis" in Prop Reg.
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