shall be the same as its value for purposes of chapter 11 (determined with regard to sections 2032 and 2032A). (c) Alternate valuation election permitted in the case of taxable terminations occurring at deathIf 1 or more taxable terminations with respect to the same trust occur at the same time as and as a result of the death of an individual, an

) Would contain a minimum quantity of spirits, taking into account the procedure employed, would not be subjected to further operations solely for the purification or recovery of spirits, and would be found by TTB to be as nonpotable and as difficult to recover as completely denatured alcohol. (26 U.S.C. 5201)

(i) the day 10 days after the date of the first delinquency notice to the taxpayer under section 6303, or (ii) the day on which notice and demand for immediate payment is given under section 6861 or 6862 or the last sentence of

, and (2) The $25,000 amount specified in section 50A(a)(2), relating to limitation based on amount of tax, shall be reduced by 50 percent of such amount. For example, a domestic building and loan association incurs $30,000 in WIN expenses (as determined under paragraph (a) of §1.50B-1) during its taxable year. However

(a) General rules for when amounts are included in gross income. Except as provided in this section (or in §1.403(b)-10(c) relating to payments pursuant to a qualified domestic relations order), amounts actually distributed from a section 403(b) contract are includible in the gross income of the recipient participant or

§1.871-7. Thus, an individual within this class shall not be allowed any deductions for the personal exemptions otherwise allowed by section 151 or 642(b). (ii) Source of losses. Notwithstanding the provisions of section 873(b)(1), losses from sales or exchanges of capital assets shall be allowed under this subparagraph only

(a) Bonds must be registered to be tax exempt (1) General ruleNothing in section 103(a) or in any other provision of law shall be construed to provide an exemption from Federal income tax for interest on any registration-required bond unless such bond is in registered form.

If— (1) a loss is on stock in a small business investment company operating under the Small Business Investment Act of 1958, and (2) such loss would (but for this section) be a loss from the sale or exchange of a capital asset, then such loss shall be treated as an ordinary loss. For purposes of

(a) General ruleIn the case of a taxpayer who transfers securities (as defined in section 1236(c)) pursuant to an agreement which meets the requirements of subsection (b), no gain or loss shall be recognized on the exchange of such securities by the taxpayer for an obligation under such agreement, or on the exchange of rights under

section 6114 as section 6115 of this title] shall apply to taxable periods the due date for filing returns for which (without extension) occurs after December 31, 1988."

§301.7430-2   Requirements and procedures for recovery of reasonable administrative costs. (a) Introduction. (b) Requirements for recovery. (1) Determination by the Internal Revenue Service. (i) Jurisdiction. (ii) Administrative proceeding. (iii) Administrative proceeding date. (iv) Reasonable administrative costs. (v) Prevailing

adjustment for policyholder dividendsFor purposes of this subsection, the term "1984 fresh-start adjustment for policyholder dividends" means the amounts held as of December 31, 1983, by the taxpayer as reserves for dividends to policyholders under section 811(b) (as in effect on the day before the date of the enactment of the Tax Reform Act of 1984) other than for dividends which accrued before

of the amount to which the application relates. The application, with supporting documents, must be filed with the applicable district director referred to in paragraph (a) of §25.6091-1 regardless of whether the return is to be filed with, or the tax is to be paid to, such district director on or before the date prescribed for payment of the amount with respect to which the extension is desired

not be liable for any claim arising from such disclosure brought by any customer, any party with respect to whose tax liability the summons was issued, or any other person. (2) Certificate of the Secretary. The Secretary may issue to the summoned party a certificate if the person with respect to whose liability the summons was issued expressly consents to the examination of the records summoned and the taking of testimony

§1.987-8(e). Accordingly, the remittance proportion in the case of a termination is 1. (d) Aggregate of all amounts transferred from the section 987 QBU to the owner for the taxable year. For purposes of paragraph (c)(1)(i) of this section, the aggregate amount transferred from the section 987 QBU to the owner for the taxable year shall be the aggregate amount of functional currency and the aggregate adjusted basis

(a)-(e) [Reserved] (f) Transactions between persons described in section 482 and net section 482 transfer price adjustments. For purposes of applying the reasonable cause and good faith exception of section 6664(c) to net section 482 adjustments, the rules of §1.6662-6(d) apply. A taxpayer that

(a) General ruleThe net collection of taxes imposed by chapter 1 for each taxable year with respect to an individual to whom section 931 or 932(c) applies shall be covered into the Treasury of the specified possession of which such individual is a bona fide resident. (b) Definition and special

section 2014, for any period before the receipt of such refund, except to the extent interest was paid by the foreign country on such refund. Editorial Notes Amendments

section 4217 shall apply. (3) Use treated as sale (A) In generalIf any person uses an article taxable under section 4051 before the first retail sale of such article, then such person shall be liable for tax under

(a) (1) through (a)(2) [Reserved]. For further guidance, see §1.988-1(a)(1) through (2). (3) Specified owner functional currency transactions of a section 987 QBU not treated as section 988 transactions. Specified owner functional currency transactions, as

Except as provided in sections 7470A and 7475, all fees received by the Tax Court pursuant to this title shall be deposited into a special fund of the Treasury to be available to offset funds appropriated for the operation and maintenance of the Tax Court.