The regulations may provide that income realized before the change date from discrete sales of assets would be excluded from the ratable
allocation and could be offset without limit by pre-change losses.
The regulations maintain the general rule of ratable
allocation but allow for a closing of the books election made on a timely filed return.
Thus, it makes no sense to attempt to determine the ratable
share of E&P in a corporation in which the shareholders do not have any stock ownership.
382 limitation while, under ratable
allocation, some portion of the loss would be allocated to the prechange period and subject to limitation.
The notes underlying these securities also now enjoy ratable
sharing in the pledge of Meditrust Corp.
736(b) payments to be made to a partner is fixed, however, the partner may determine the amount of gain or loss attributable to each payment by applying a ratable
portion of his basis in the partnership interest to each payment.
The agreement expires on June 10, 2002, and is secured by a lien on most of the Company's assets on an equal and ratable
basis with the Company's senior notes.
Payment method: The payment method applies to all taxpayers that have not elected the ratable
accrual method and that have not elected the recurring item exception.
Pursuant to the US Lines Plan of Reorganization, which became effective in 1990, the former unsecured creditors of US Lines became entitled to receive ratable
portions of 5,000,000 shares of the Company's Common Stock.
It will be important to identify at the top of the statement, "REQUEST TO CHANGE TO THE RATABLE
ACCRUAL METHOD FOR REAL PROPERTY TAXES UNDER REV.
Clarus anticipates that approximately 90 percent of its license business will be contracted under agreements requiring ratable
2 million (approximately 80%) of those shares into escrow with the Company's law firm, to be sold in a ratable
fashion over the next four years once the various investors' Rule 144 holding periods expire.