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88-98 held that, when a taxpayer claims an overpayment on a return filed either on the original due date or on extension and the claimed overpayment is applied in full against an installment of the succeeding year's estimated tax, interest on a subsequently determined deficiency for the earlier year runs from the due date of that installment on the part of the deficiency equal to or less than the claimed overpayment and from the original due date of the return on the remainder.
Rather than apply the entity attribution rules of section 318(a)(2) without regard to the 50-percent threshold in section 318(a)(2)(C), as in the Archer/Rath/Moynihan bill, the House bill applied section 355(d)(8)(A), which incorporates section 318(a)(2), but attributes stock owned by a corporation to its shareholder only if the shareholder owns 10 percent of the corporation.

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