67(e)(1) "serves as a filter" with respect to the first clause and "treats as fully deductible only those trust-related administrative expenses that are unique to the administration of a trust and not customarily incurred
outside of masts" Id.
In general, the proposed regulations' treatment of costs incurred
to acquire or produce tangible property largely restates existing law.
461(h)(1) provides that, in determining whether an amount has been incurred
with respect to any item during any tax year, the all events test shall not be treated as met any earlier than when economic performance with respect to such item occurs.
The IRS said that, as many individuals do hire investment advisers, the expenditures for investment advice were not incurred
because of the trust's existence.
First, there will be claimants who are aware of a contamination problem but who yet have not incurred
significant investigative or cleanup costs.
The 2004 IRS regulations requiring the capitalization of a lender's loan expenses are generally effective for expenses incurred
on or after December 31, 2003, although expenses which have been previously incurred
may also be affected by the new regulations.
tax cost incurred
or accelerated as a result of purchaser making a 338(g) election.
The Mooney Award consists of $3,000, a plaque and lifetime membership to the Rubber Division, plus $500 for travel expenses incurred
to attend the awards ceremony.
Acquisition indebtedness incurred
prior to October 14, 1987, is not subject to the limitations imposed on indebtedness incurred
274(e)(3) might apply because the per-diem expenses were "paid or incurred
by the taxpayer ...
The regulations require taxpayers to capitalize costs incurred
to create or enhance a "future benefit identified in published guidance in the Federal Register or the Internal Revenue Bulletin ...
In other words it treated the lees as costs incurred
on a normal business loan.