(a) Citizens or residents. The return of an estate of a decedent who was a citizen or resident of the United States at the time of his death must contain an itemized inventory by schedule of the property constituting the gross estate and lists of the deductions under the proper schedules. The return shall set forth (1) the value of the gross estate (see

(a) In general. An imputed underpayment determined under subchapter C of chapter 63 of the Internal Revenue Code (Code) is assessed and collected in the same manner as if the imputed underpayment were a tax imposed by subtitle A of the Code for the adjustment year (as defined in §301.6241-1(a)(1)) except that the deficiency

, an individual derives $10,000 of ordinary income from passive activity X, no gains from the sale or exchange of capital assets or assets used in a trade or business, $12,000 of capital loss from passive activity Y, and no income, gain, deductions, or losses from any other passive activity. The capital loss from activity Y is a passive activity deduction (within the meaning of §1.469-2T(d)). Under

), the following shall be treated as related persons— (A) 2 or more persons if the relationship between such persons would result in a disallowance of losses under section 267 or 707(b), (B) 2 or more persons which are members of the same controlled group of corporations (as defined in

163(e), sections 1271 through 1275, and the corresponding regulations. In addition, the anti-abuse rule in §1.1275-2(g) applies for purposes of this section. For rules dealing with the treatment of bond premium by a holder, see §§1.171-1 through 1.171-5. (b)

(1) The owner's net unrecognized section 987 gain or loss with respect to the section 987 QBU determined under §1.987-4 on the last day of such taxable year (or, if earlier, on the day the section 987 QBU is terminated under §1.987-8); multiplied by (2) The owner's

(a) Scope. This section provides rules concerning the application of the limitations of section 501(h) to members of an affiliated group of organizations (as defined in §56.4911-7(e)(1)). (b) Determination required. For each taxable year of an affiliated

(a) Property acquired by issuance of stock or as paid-in surplusIf property was acquired by a corporation— (1) in connection with a transaction to which section 351 (relating to transfer of property to corporation controlled by transferor) applies, or (2) as paid-in

(a) Classes of aliens. For purposes of the income tax, alien individuals are divided generally into two classes, namely, resident aliens and nonresident aliens. Resident alien individuals are, in general, taxable the same as citizens of the United States; that is, a resident alien is taxable on income derived from all sources, including sources without the United States. See

(a) Interest and penalties with respect to the reviewed year. Except to the extent provided in section 6226(c), in the case of a partnership adjustment (as defined in §301.6241-1(a)(6)) for a reviewed year (as defined in §301.6241

States. (i) Export warehouse proprietor"Export warehouse proprietor" means any person who operates an export warehouse. (j) Removal or remove"Removal" or "remove" means the removal of tobacco products or cigarette papers or tubes, or any processed tobacco, from the factory or from internal revenue bond under

(a) In general. This section coordinates the withholding requirements of a withholding agent when a withholdable payment or foreign passthru payment is subject to withholding under both chapter 4 and another Code provision. See §1.1473-1(a) for the definition of withholdable payment and see

Sections 1.6015-0 through 1.6015-9 are applicable for all elections under §1.6015-2 or 1.6015-3 or any requests for relief under §1.6015-4 filed on or after July 18

Except as otherwise provided by §301.6323(h)-1 the definitions provided by §301.6323(h)-1 apply for purposes of §§301.6323(a)-1 through

If the certificate prescribed in §26.205 covers beer, the beer tax will be collected at the rates imposed by 26 U.S.C. 5051. (68A Stat. 611, as amended;

paragraph (3). A rule similar to the rule of paragraph (4) shall apply in the case of any person whose basis in any bond or coupon is determined by reference to the basis of the person described in the preceding sentence. (c) Special rules for tax-exempt obligations (1) In generalIn the case of any tax-exempt obligation (as defined in

(A) the qualified direct cost for such taxable year, and (B) subject to the limitation of section 419A(b), any addition to a qualified asset account for the taxable year. (2) Reduction for funds after-tax incomeIn the case of any welfare benefit fund, the qualified cost for any taxable year shall be reduced by

(a) General rule. Except as otherwise provided in paragraph (b) of this section, an issuer (including a transferee) determines the amount of OID that is deductible each year under section 163(e)(1) by using the constant yield method described in §1.1272-1(b). This determination, however, is made without regard to section 1272(a