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75-223, the proceeds attributable to the D and C businesses of F-Sub (as a result of the deemed sale by Target of F-Sub stock) were not distributable in partial liquidation and were retained by Parent.
Accordingly, in the example above, to change to an accounting method under which X could deduct in 2005 the insurance premium and equipment rental payments attributable to 2006, X would have to file two Forms 3115--one under the automatic consent procedure by the due date of the 2005 return to change to the 12-month rule for both payments, and the other under the advance consent procedure, which would have to be filed by Dec.
Recording one quarter of its share of income (its share of income items exceeding its share of expense items attributable to the partnership's or corporation's short year) on a timely filed original return for the partner's or shareholder's year with, or within, which the partnership's or corporation's short year ends or an amended return filed before April 13, 2004 if the partner or shareholder has timely filed a return before Nov.
Schleier received a substantial award, half attributable to "back pay" and the balance to "liquidated damages.
First, the prior law negligence penalty applied to the entire underpayment if any part of the underpayment was attributable to negligence.
For an item not attributable to a tax shelter, Sec.
That is, despite the fact the costs were incremental in nature, directly attributable to the acquisition and incurred in integrating the acquired entity, the SEC found they were improperly capitalized.
Specifically, we believe that section 6404(e) should be amended to provide for the mandatory abatement of interest under section 6621(c) during the period attributable to a delay by the IRS in considering the taxpayer's administrative appeal of proposed adjustments.
401(a)(11) and 417 apply to all "benefits provided under a plan, including benefits attributable to rollover contributions" (Regs.
Rent from real property includes that attributable to incidental personal property (as long as it is no more than 15% of the total rent) and includes charges for services customarily furnished in connection with the rental of real property.
The proposed regulations address the extent to which certain ratemaking procedures and adjustments that are based on tax savings attributable to the filing of a consolidated return will be treated as inconsistent with the Code's normalization requirements.