disallowed


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References in periodicals archive ?
it retained the present investment adjustment rules but disallowed any loss on the disposition by P of its S stock on or after March 9, 1990.
Permanently suspended losses and disappearing depreciable basis: As discussed, if any of the transferred assets have a built-in loss and the creditor-partner is related to the partnership, the loss could be disallowed at the partnership level.
The issue before the court--one not previously heard by the Second Circuit or any other court of appeals--was whether the deduction for real property taxes permitted by section 216 had been disallowed for AMT purposes.
Specifically, if tracing is not acceptable, the disallowed loss should be limited to net built-in gain at the acquisition date.
However, even when a claim is disallowed under such circumstances, GCM 38786 notes that the taxpayer "should be allowed to reopen the claim if it subsequently obtains the additional evidence needed to prove its right to a refund, provided that the Service has sufficient time to reconsider the claim prior to the expiration of the period of limitations prescribed in section 6532(a).
481 US 239, in which the Supreme Court disallowed a deduction for the estimated costs of employee medical expenses under a medical reimbursement plan.
He said: "We're stunned the goal was disallowed but luck has gone against us all season.
The Act also provides that orphan drug credits currently not utilizable due to the imposition of the AMT will increase the MTC with respect to credits disallowed after December 31, 1986; this effectively creates an indefinite carryforward period for this item.
If evidence is not collected strategically, there is a great risk of evidence being disallowed in court or missed altogether," said customer Patrick Tagtow, senior legal counsel for BMC Software, Inc.
Walkom disallowed the apparent goal and could not be dissuaded by the heated argument waged by Blake and Luc Robitaille.
Hispanic Broadcasting Corporation (NYSE:HSP) announced today the Department of Justice (DOJ) has disallowed Hispanic Broadcasting Corporation's (HBC) proposed $127 million acquisition of three radio stations in the Denver, Austin and Phoenix markets that the DOJ required to be divested by Clear Channel Communications, Inc.
Interest deductions related to debt obligations issued as a dividend or paid in lieu of dividends also will be disallowed, unless the Director is satisfied that tax avoidance is not a significant purpose of the transaction.