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foreign corporation, followed by the complete liquidation of the domestic corporation into the common parent, and "(2) qualifies, pursuant to Revenue Ruling 87–27, as a reorganization which is described in section 368(a)(1)(F) of the 1986 Code, then, solely for purposes of applying Treasury Regulation
(a) General. If there is a change relating to any of the information contained in, or considered a part of, the application on form TTB F 5110.74, Application and Permit for an Alcohol Fuel Producer Under 26 U.S.C. 5181, the proprietor must amend the information previously submitted within 30 days of the change unless another time
) Of the circumstances indicating diversion or theft; (d) That allowance of the loss will be subject to filing (1) proof that such loss is allowable under the provisions of 26 U.S.C. 5370, and (2) claim for remission of the tax on the wine so lost; and (e) That action in respect of the loss will be withheld for a period of not more than 30
(a) General ruleGross income shall include an amount equal to any illegal Federal irrigation subsidy received by the taxpayer during the taxable year. (b) Illegal Federal irrigation subsidyFor purposes of this section— (1) In generalThe term "illegal Federal irrigation subsidy" means the excess (if any) of—
(a) Definitions. The definitions in this section apply to this section and §§1.45R-2, 1.45R-3, 1.45R-4, and 1.45R-5. (1) Average premium. The term average premium means an average premium for the small group market in
(a) In general. Section 179(a) allows a taxpayer to elect to expense the cost (as defined in §1.179-4(d)), or a portion of the cost, of section 179 property (as defined in §1.179-4(a)) for the taxable year in which the property is
return for the group in accordance with§1.6033-2(d); and (8) Any organization no longer exempt from taxation under section 501(a) and that during the period of its exemption under such section was not an organization described in section 501(c)(3), a corporation described in section 501(c)(2) that held title to property for an organization described in section 501(c
26 U.S.C. 6103 or section 1106 of the Social Security Act, 42 U.S.C. 1306), Executive Order, or regulation (such as 20 CFR part 401)? (2) Would providing the testimony put confidential, sensitive, or privileged information at risk? (b
Treasury. (The preceding sentence shall not apply to matters relating to individuals benefits.) (b) Notification to Secretary of Labor before Secretary of the Treasury sends notice of deficiency under section 4971 of title 26; waiver of imposition of tax; requests for investigation; consultationUnless the Secretary of the Treasury finds that the collection
list must be updated during performance of the contract whenever the Contractor determines that any other material to be delivered under this contract is hazardous. (d) The apparently successful offeror agrees to submit, for each item as required prior to award, a Material Safety Data Sheet, meeting the requirements of 29 CFR 1910.1200(g) and the latest version of Federal Standard No. 313, for all hazardous material identified in paragraph (b) of this clause. Data shall be submitted in
consolidated U.S.-source taxable income or CDL. The group computes its consolidated separate limitation income (CSLI) or consolidated separate limitation loss (CSLL) for each separate category under the principles of §1.1502-11 by aggregating each member's foreign-source taxable income or loss in such separate category computed under the principles of
on behalf of an owner-employee, the rules of this section are modified by the rules of paragraph (b) of §1.72-17. Further, in applying the provisions of this section, the aggregate premiums or other consideration paid shall not include contributions on behalf of self-employed individuals to the extent that deductions were allowed under section 404 for such contributions. Nor, shall the aggregate of
accordance with this section to the transfer of estates of decedents who were residents of such foreign country, the President shall proclaim that the tax on the transfer of the estate of every decedent who was a resident of such foreign country at the time of his death shall, in the case of decedents dying after the date of such proclamation, be determined under this subchapter without regard to amendments made to
section 7425(b). Section 301.7425-2 contains rules with respect to the nonjudicial sales described in section 7425(b). Paragraph (a) of §301.7425-3 contains rules with respect to the notice of sale provisions of section 7425(c)(1). Paragraph (b) of
(a) Scope. This section prescribes rules for qualification for a section 338(h)(10) election and for making a section 338(h)(10) election. This section also prescribes the consequences of such election. The rules of this section are in addition to the rules of §§1.338-1 through 1.338-10 and, in appropriate cases, apply instead of
§601.504 of this chapter (Statement of Procedural Rules). (b) Evidence of authority to sign. A partner's signature on a return, statement, or other document made by or for a partnership of which he is a member shall be prima facie evidence that such partner is authorized to sign such return, statement, or other document. (c) Certain
meaning of important terms in the Act; (3) Prescribes the procedures for applying for an exemption from the Act and the regulations issued under the Act and a listing of exemptions. (b) Nothing in this part relieves any person from the obligation of complying with the rules of the road and the applicable pilot rules. {"origins":[{"level":"part","identifier
address code allows an activity to order supplies under the FEDSTRIP system. Because there is a potential for abuse in the use of these codes, agencies shall establish stringent internal controls to ensure that the codes are used only by authorized personnel. It is imperative that all requests for activity address codes or deletions or address changes flow through a central contact point in the agency headquarters or regions where the need, purpose, and validity of the request can be verified
surtax, as well as normal tax, on the increase in its mutual insurance company taxable income for the taxable year which is attributable to such election. Similarly, any amount which was added to the protection against loss account by reason of an election under section 826(a) and §1.826-1, and which is subtracted from such account in accordance with section 826(d) and paragraph (a) of this section
(a) Except as provided in paragraph (b) of this section, the contracting officer shall insert the clause at 52.246-26, Reporting Nonconforming Items, in solicitations and contracts—as follows: (1) For an acquisition by any agency, including the Department of Defense, of— (i) Any items that are
and retain a copy for his files. (Approved by the Office of Management and Budget under control number 1512-0203) (Sec. 201, Pub. L. 85-859, 72 Stat. 1366, as amended (26 U.S.C. 5232); Sec. 6, Pub. L. 96-598, 94 Stat. 3488, as amended (