(a) In generalWithin 90 days after the date on which a notice of a final partnership adjustment is mailed under section 6231 with respect to any partnership taxable year, the partnership may file a petition for a readjustment for such taxable year with— (1) the Tax Court,

which it is produced, contains no more alcohol than is reasonably unavoidable in the manufacture of such concentrate; and (2) such concentrate is rendered unfit for use as a beverage before removal from the place of manufacture, or (in the case of a concentrate which does not exceed 24 percent alcohol by volume) such concentrate is transferred to a bonded wine cellar for use in production of natural wine as provided in

(B) is held primarily for sale to customers in the ordinary course of the taxpayer's trade or business, (C) is held by a bank (as defined in section 581), (D) is held by a regulated investment company or a common trust fund, (E) is identified by the taxpayer under

section 6111. Subparagraph (B) shall be applied by substituting "75 percent" for "50 percent" in the case of an intentional failure or act described in subsection (a). (c) Rescission authorityThe provisions of section 6707A(d) (relating to authority of Commissioner to rescind penalty) shall apply

section 5061(d)(4) applies to a taxpayer (determined after application of subparagraph (B) thereof), such taxpayer shall not be required to furnish any bond covering operations or withdrawals of distilled spirits or wines for nonindustrial use or of beer. (2) Satisfaction of bond requirementsAny taxpayer for any period described in paragraph (1) shall be treated as if sufficient bond has been

property so transferred, over (2) the adjusted basis (for purposes of determining gain) of such property in the hands of the transferor. (b) ExceptionSubsection (a) shall not apply to a transfer to a trust by a United States person to the extent that any person is treated as the owner of such trust under section 671.

(a) An adjustment under the circumstances stated in paragraph (b) of §1.1312-3 (relating to the double exclusion of an item of gross income) which would result in an additional assessment, is authorized only if assessment of a deficiency against the taxpayer or related taxpayer for the taxable year in which the item is includible was not barred by any law or rule of

§1.1248-8) by such person while such corporation was a controlled foreign corporation. See section 1248(a). See §1.1248-8 for additional rules regarding the attribution of earnings and profits to the stock of a foreign corporation following certain nonrecognition transactions. For computation of earnings and profits attributable to such stock if there

(a) In general. The provisions of §§1.1362-1 through 1.1362-6 apply to taxable years of corporations beginning after December 31, 1992. For taxable years to which these regulations do not apply, corporations and shareholders subject to the provisions of section 1362 must take reasonable return positions taking into consideration

to the public. An unsupported claim to be doing research for a book or article does not demonstrate that likelihood, while such a claim by a representative of the news media is better evidence; and (4) Whether the contribution to public understanding will be a significant one, i.e., will the public's understanding of the Government's operations be substantially greater as a result of the disclosure. (c)

section 4053(8). (d) BiasplyFor purposes of this part, the term "biasply tire" means a pneumatic tire on which the ply cords that extend to the beads are laid at alternate angles substantially less than 90 degrees to the centerline of the tread. (e) Super single tireFor purposes of this part, the term "super single tire

prescribed by the Secretary) to income of such related person which is not passive income, or (D) which is export trade income of an export trade corporation (as defined in section 971). For purposes of subparagraph (C), the term "related person" has the meaning given such term by

. By express or overnight mail. You may send written comments to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS–9904–P, Mail Stop C4–26–05, 7500 Security Boulevard, Baltimore, MD 21244–1850. For information on viewing public comments, see the beginning of the

(a) Accumulated earnings taxIn the determination of the dividends paid deduction for purposes of the accumulated earnings tax imposed by section 531, a dividend paid after the close of any taxable year and on or before the 15th day of the fourth month following the close of such taxable year shall be considered as paid during such

(1) EntityIn the case of a tax-exempt entity— (A) In generalExcept as provided in subparagraph (B), the amount of the tax imposed under subsection (a)(1) with respect to any transaction for a taxable year shall be an amount equal to the product of the highest rate of tax under section 11, and the greater of

an option described in section 423(c) (relating to special rule where option price is between 85 percent and 100 percent of value of stock), shall, for such calendar year, make a return at such time and in such manner, and setting forth such information, as the Secretary may by regulations prescribe. (b) Statements to be

. In general, export property is certain property held for sale or lease which meets the requirements of §1.993-3. (c) Business assets. For purposes of this section, business assets are assets used by a DISC (other than as a lessor) primarily in connection with— (1) The sale, lease, storage

(a) Failures to pay (1) Premiums for eligible beneficiariesThere is hereby imposed a penalty on the failure of any assigned operator to pay any premium required to be paid under section 9704 with respect to any eligible beneficiary. (2