(iii) included in gross income by reason of section 402(b) (relating to taxability of beneficiary of nonexempt trust) or section 403(c) (relating to taxability of beneficiary under a nonqualified annuity), or (iv) received after the

(2) the amount of any interest payable on the obligation (other than interest taken into account in determining the amount of the acquisition discount) which accrues during the taxable year while the taxpayer held such obligation (and is not included in the gross income of the taxpayer for such taxable year by reason of the taxpayer's method of accounting). (b) Section not to apply to obligations to which

(a) ScopeSubject to the limitations contained in this chapter, the tax imposed by section 2501 shall apply whether the transfer is in trust or otherwise, whether the gift is direct or indirect, and whether the property is real or personal, tangible or intangible; but in the case of a nonresident not a citizen of the United States

(a) In generalThere shall be allowed as a deduction an amount equal to the qualified overtime compensation received during the taxable year and included on statements furnished to the individual pursuant to section 6041(d)(4) or 6051(a)(19). (b) Limitation

(a) Purchasing manufacturer to be treated as the manufacturerFor purposes of this chapter, a manufacturer or producer to whom an article is sold or resold free of tax under section 4221(a)(1) for use by him in further manufacture shall be treated as the manufacturer or producer of such article.

(a) Computation of taxThe tax imposed by section 2501 for each calendar year shall be an amount equal to the excess of— (1) a tentative tax, computed under section 2001(c), on the aggregate sum of the

(a) General ruleFor purposes of section 38, the employer social security credit determined under this section for the taxable year is an amount equal to the excess employer social security tax paid or incurred by the taxpayer during the taxable year. (b) Excess employer social security tax

received in exchange for property shall be the fair market value of such property adjusted to take into account other consideration involved in the transaction. (B) Potentially abusive situation definedFor purposes of subparagraph (A), the term "potentially abusive situation" means— (i) a tax shelter (as defined in

meaning of section 416(i)(1)), subsection (a) shall not apply to any benefit attributable to a plan for which the qualified benefits provided to key employees exceed 25 percent of the aggregate of such benefits provided for all employees under the plan. For purposes of the preceding sentence, qualified benefits shall be determined without regard to the second sentence of subsection (f).

(a) General ruleExcept as otherwise provided in this section, the allowance for depletion under section 611 with respect to any oil or gas well shall be computed without regard to section 613. (b

(a) In general. Partnership adjustments (as defined in §301.6241-1(a)(6)) that do not result in an imputed underpayment (as described in §301.6225-1(f)) are taken into account by a partnership in the adjustment year (as

(a) In generalNotwithstanding any other provision of law, any individual to whom section 877(b) or 877A applies for any taxable year shall provide a statement for such taxable year which includes the information described in subsection (b). (b) Information to be providedInformation

In the case of a small business investment company operating under the Small Business Investment Act of 1958, if— (1) a loss is on stock received pursuant to the conversion privilege of convertible debentures acquired pursuant to section 304 of the Small Business Investment Act of 1958, and

(a) General ruleGain from the sale or exchange of a patent, an invention, model, or design (whether or not patented), a copyright, a secret formula or process, or any other similar property right to any foreign corporation by any United States person (as defined in section 7701(a)(30)) which controls such foreign corporation shall, if

(a) WagesFor purposes of this subpart— (1) In generalThe term "wages" has the same meaning as when used in section 51. (2) Certain training and educational benefits (A) In generalThe

(a) Interest on judgments for overpaymentsFor interest on judgments for overpayments, see 28 U.S.C. 2411(a). (b) AdjustmentsFor provisions prohibiting interest on certain adjustments in tax, see

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

, (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),