We will also clearly define when a superior is liable for COA suspension and disallowances
as well as how a subordinate can steer clear of liabilities for an irregular act committed by his/her superior.
The regulations did not provide any additional guidance defining entertainment use; (27) however, they do provide in-depth mechanical rules in calculating the entertainment disallowance
percentage (once the purpose of individual passengers' travel is determined).
The salient theoretical objection to a backward disallowance
rule is that such a rule would undermine the statutory exclusions.
The appeals court held that the disallowance
of the deduction of the inventory purchased was a change in India Music's accounting method, since the timing of the deduction was altered, causing a change in the treatment of a material item in 2004.
The loss disallowance
rules in effect up until the issuance of Regs.
But, from April, 2009, the Chancellor has swept that disallowance
away and replaced it with a restriction based on CO2 emissions.
They side-step difficult issues such as how section 274(e)(2) relates to such matters as the rules pertaining to entertainment facilities under section 274(a)(1)(B) and the other disallowance
provisions within section 274, as well as the valuation of fringe benefits.
61-21(g), the employer satisfies the requirements for the exception to the deduction disallowance
The comprehensive and complex loss disallowance
rule is often cited as the major disadvantage in electing to file a consolidated tax return.
AMT permits a disallowance
of 90 percent of the NOLs, leaving 10 percent of the NOLs as a tax liability.
A statistical projection of these audit disallowances
to the entire population using a 95% single-sided confidence level, resulted in an audit disallowance