(a) Inclusion (1) In generalEvery United States person who owns (or is treated under section 1298(a) as owning) stock of a qualified electing fund at any time during the taxable year of such fund shall include in gross income— (A) as ordinary income

(a) Creation of remedyIn a case of actual controversy involving— (1) a determination by the Secretary— (A) with respect to the initial qualification or continuing qualification of an organization as an organization described in section 501(c)(3) which is exempt

(a) Imposition of taxIf— (1) there is a prohibited allocation of qualified securities by any employee stock ownership plan or eligible worker-owned cooperative, (2) there is an allocation described in section 664(g)(5)(A), (3

(a) Annual registration (1) General ruleWithin such period after the end of a plan year as the Secretary may by regulations prescribe, the plan administrator (within the meaning of section 414(g)) of each plan to which the vesting standards of

(a) Revenue Act of 1932If the property was acquired, after February 28, 1913, in any taxable year beginning before January 1, 1934, and the basis thereof, for purposes of the Revenue Act of 1932 was prescribed by section 113(a)(6), (7), or (9) of such Act (47 Stat. 199), then for purposes of this subtitle the basis shall be the same as

(a) LimitationThe total amount of the credit taken under section 901(a) shall not exceed the same proportion of the tax against which such credit is taken which the taxpayer's taxable income from sources without the United States (but not in excess of the taxpayer's entire taxable income) bears to his entire taxable income for the same

(a) Determining whether adjustments result in an imputed underpayment—(1) Determination of an imputed underpayment. The determination of whether adjustments requested in an administrative adjustment request (AAR) result in an imputed underpayment in the reviewed year (as defined in §301.6241-1

(i) Short-term obligationsAny obligation with a fixed maturity date not exceeding 1 year from the date of issue. (ii) United States savings bondsAny United States savings bond. (iii) Installment obligationsAny installment obligation to which section 453B

For purposes of this part, the term "life insurance deductions" means the general deductions provided in section 805. Editorial Notes

(a) Invalidity of lien without notice. The lien imposed by section 6321 is not valid against any purchaser (as defined in paragraph (f) of §301.6323(h)—1), holder of a security interest (as defined in paragraph (a) of

(a) Collection of liability. Any money realized by proceedings under 26 U.S.C. 6331 through 6344, or by sale of property redeemed by the United States (if the interest of the United States in the property was a lien arising under the provisions of 26 U.S.C. enforced and administered by the Bureau), is applied in the manner specified

Section 1297(d) shall not apply in determining whether a corporation is a passive foreign investment company for purposes of this subparagraph. (3) Partnerships, etc.Stock owned, directly or indirectly, by or for a partnership, estate, or trust shall be considered as being owned proportionately by its partners or beneficiaries. (4

if payment of dependent care assistance for such services occurs in a subsequent taxable year). (C) Marital statusFor purposes of this paragraph, marital status shall be determined under the rules of paragraphs (3) and (4) of section 21(e). (D) Special rule for 2021In the case of any taxable

) Noncompliance periodsA day is described in this subsection with respect to a designated drug if it is a day during one of the following periods: (1) The period beginning on the March 1st (or, in the case of initial price applicability year 2026, the October 2nd) immediately following the date on which such drug is included on the list published under section 1192(a)

(a) In general. A corporation that issues fast-pay stock in a fast-pay arrangement described in §1.7701(l)-3(b)(1) is a withholding agent with respect to payments made on the fast-pay stock and payments deemed made under the recharacterization rules of