(a)(1) shall not submit an annual electronic notification under section 6033(i). This includes the following types of organizations: (i) Any organization included in a group return for that year under §1.6033-2(d). (ii) All private foundations required to file under

§1.72-13, or (b) certain annuities described in section 72(o) and §1.122-1), an exclusion ratio is to be determined for each contract. In general, this ratio is determined by dividing the investment in the contract as found under

paragraph with respect to a transaction described in subparagraph (E) or (F) of paragraph (1) unless the Secretary affords an opportunity for a hearing and makes a determination on the record with respect to the findings required under subparagraphs (A), (B), and (C) of this paragraph, except that in lieu of such hearing the Secretary may accept any record made by the Secretary of Labor with respect to an application for exemption under

taxable year of the discharge, and any net operating loss carryover to such taxable year. (B) General business creditAny carryover to or from the taxable year of a discharge of an amount for purposes for determining the amount allowable as a credit under section 38 (relating to general business credit). (C

day on which the election was made the corporation did not meet the requirements of subsection (b) of section 1361, or (ii) 1 or more of the persons who held stock in the corporation during such taxable year and before the election was made did not consent to the election, then such election shall be treated as made for the

, (3) $50,000 for any one calendar year, in the case of the tax imposed by chapter 12, or (4) $50,000 for any 1 taxable period (or, if there is no taxable period, taxable event) in the case of any tax imposed by subtitle D which is described in section 6212(a) (relating to a notice of deficiency),

interest, additional amounts, and additions to the tax provided for by law). Such tax, additions to the tax, and interest shall thereupon become immediately due and payable, and immediate notice and demand shall be made by the Secretary for the payment thereof. (b) Immediate levyFor provision permitting immediate levy in case of jeopardy, see section 6331(a)

(a) Liability for penaltyAny person who— (1) has a duty to report or may have a duty to report any information under section 6047(d), and (2) fails to keep such records as may be required by regulations prescribed under

(b) Holding period for distributed propertyIn determining the period for which a partner has held property received in a distribution from a partnership (other than for purposes of subsection (a)(2)), there shall be included the holding period of the partnership, as determined under section 1223, with respect to such property. (c) Special

which the taxpayer's modified adjusted gross income exceeds $150,000 ($300,000 in the case of a joint return). (B) Modified adjusted gross incomeFor purposes of this paragraph, the term "modified adjusted gross income" means the adjusted gross income of the taxpayer for the taxable year increased by any amount excluded from gross income under section 911

(a) General ruleNo deduction shall be allowed to the issuing corporation for any premium paid or incurred upon the repurchase of a bond, debenture, note, or certificate or other evidence of indebtedness which is convertible into the stock of the issuing corporation, or a corporation in the same parent-subsidiary controlled group (within the meaning of

any calendar year, the sum of— (A) the deduction for dividends paid (as defined in section 561) during such calendar year (but computed without regard to that portion of such deduction which is attributable to the amount excluded under section 857(b)(2)(D)), and

chapter 2, 2A, 3, or 4 of the Code. Accordingly, for purposes of determining taxes imposed under chapters of the Code other than chapter 1, the Internal Revenue Service (IRS) may make an adjustment to any partnership-related item (as defined in §301.6241-1(a)(6)(ii)) in a proceeding that is not under subchapter C of chapter 63. To the extent an adjustment or determination is made under subchapter C

(B) Exceptions for tax-exempt obligationsThe term "short-term obligation" shall not include any tax-exempt obligation (as defined in section 1275(a)(3)). (2) Acquisition discountThe term "acquisition discount" means the excess of— (A) the stated redemption price at maturity

site employee, and (2) the exemptions, exclusions, definitions, and other rules which are based on type of employer and which would (but for paragraph (1)) apply shall apply with respect to such taxes imposed on such remuneration. (b) Successor employer statusFor purposes of sections 3121(a)(1), 3231(e)(2)(C), and 3306

Except for purposes of subsections (g) and (h), the term "related person" means— (A) a person whose stock would be attributed under section 318(a) (other than paragraph (4) thereof) to the person first disposing of the property, or (B) a person who bears a relationship described in

A proprietor may withdraw spirits without payment of tax for transfer to a bonded wine cellar for use in the production of nonbeverage wine and nonbeverage wine products in accordance with part 24 of this chapter. The proprietor, as consignor, must prepare a transfer record in accordance with §19.620. In addition, the proprietor must prepare a package gauge record in