For limitation period in case of— (1) Adjustments to accrued foreign taxes, see section 905(c). (2) Change of treatment with respect to itemized deductions where taxpayer and his spouse make separate returns, see

section 736(a), to a retiring partner or successor in interest of a deceased partner. (3) Substantial appreciationFor purposes of paragraph (1)— (A) In generalInventory items of the partnership shall be considered to have appreciated substantially in value if their fair market value exceeds 120 percent of the adjusted

For AST, Inc. service information identified in this NPRM, contact: AST, Inc., 34976 Kamph Drive NE, Albany, OR 97322. For JJASPP Engineering Services, LLC service information identified in this NPRM, contact: JJASPP Engineering Services, LLC, 511 Harmon Terrace, Arlington, TX 76010; phone: (817) 465-4495; website: www.jjaspp.com.

(a) Treatment as employees of domestic parent corporation (1) In generalFor purposes of applying this part with respect to a pension, profit-sharing, or stock bonus plan described in section 401(a) or an annuity plan described in

(a) General ruleNo deduction shall be allowed for the following taxes: (1) Federal income taxes, including— (A) the tax imposed by section 3101 (relating to the tax on employees under the Federal Insurance Contributions Act);