(A) there is an installment agreement between the taxpayer and the Secretary, prior to the date which is 90 days after the expiration of any period for collection agreed upon in writing by the Secretary and the taxpayer at the time the installment agreement was entered into; or (B) there is a release of levy under section 6343 after such 10-year period, prior

the taxpayer for the preceding taxable year, exceeds (B) the threshold amount. (2) Threshold amountFor purposes of paragraph (1)(B), the threshold amount shall be— (A) in the case of a joint return or a surviving spouse (as defined in section 2(a)), $150,000,

section 1297) with respect to the shareholder and which is not a controlled foreign corporation. (c) Foreign-source portionFor purposes of this section— (1) In generalThe foreign-source portion of any dividend from a specified 10-percent owned foreign corporation is an amount which bears the same ratio to such dividend as

(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

(a) In generalIf, during any calendar year, any United States citizen or resident receives any covered gift or bequest, there is hereby imposed a tax equal to the product of— (1) the highest rate of tax specified in the table contained in section 2001(c) as in effect on the date of such receipt, and

(a) Scope. This section provides rules applicable to dispositions of MACRS property (as defined in §1.168(b)-1(a)(2)) or to depreciable property (as defined in §1.168(b)-1(a)(1)) that would be MACRS property but for an

obligations described in this paragraph (b), see §1.1441-1(b)(4)(i). See §1.1471-2 for rules relating to withholding under chapter 4 of the Code that may apply to withholdable payments (as defined in §1.1471-4

section 1397C(b)) during substantially all of the taxpayer's holding period for such stock, paragraph (1) shall be applied by substituting "60 percent" for "50 percent". (B) Certain rules to applyRules similar to the rules of paragraphs (5) and (7) of

(a) Election as to real property income. A foreign corporation which during the taxable year derives any income from real property which is located in the United States, or derives income from any interest in any such real property, may elect, pursuant to section 882(d) and §1.871-10, to treat all such income as income which is

This section lists the captions contained in §§1.5000C-1 through 1.5000C-7. §1.5000C-1   Tax on specified Federal procurement payments. (a

refund" have the respective meanings given to such terms by section 6696(e), and the term "return period" has the meaning given to such term by section 6060(c).

qualifying children (within the meaning of section 24(c)) of the taxpayer. (b) Treatment of creditThe credit allowed by subsection (a) shall be treated as allowed by subpart C of part IV of subchapter A of chapter 1. (c) Limitation based on adjusted gross incomeThe amount of the credit allowed by subsection (a

(a) Authority of SecretaryIf any person liable to pay any tax neglects or refuses to pay the same within 10 days after notice and demand, it shall be lawful for the Secretary to collect such tax (and such further sum as shall be sufficient to cover the expenses of the levy) by levy upon all property and rights to property (except such property as is exempt under

(i) Specified employeesIn the case of any specified employee, the requirement of subparagraph (A)(i) is met only if distributions may not be made before the date which is 6 months after the date of separation from service (or, if earlier, the date of death of the employee). For purposes of the preceding sentence, a specified employee is a key employee (as defined in section 416(i)

included in their gross income except to the extent excluded under the accountable plan provisions of §1.62-2. (c) Payment to charitable, etc., organization on behalf of person rendering services. The value of services is not includible in gross income when such services are rendered directly and gratuitously to an organization

(a) In general. Each material advisor, as defined in §301.6111-3(b), with respect to any reportable transaction, as defined in §1.6011-4(b) of this chapter, shall prepare and maintain a list in accordance with paragraph (b) of

wages and salaries are capitalized the amount subject to depreciation must be reduced by an amount equal to the amount of the credit (determined without regard to the provisions of section 53) in determining the depreciation deduction. In the case of an employer who uses the full absorption method of inventory costing under §1.471-11, the portion of the basis of the inventory attributable to the wage

An adjustment in the case of the taxpayer with respect to whom the error was made may be authorized under section 1311 although the determination is made with respect to a different taxpayer, provided that such taxpayers stand in one of the relationships specified in section 1313(c). The concept of related taxpayer has application to all of the circumstances of adjustment specified in

(a) In general. (1) For taxable years beginning after December 31, 1962, farmers', fruit growers', or like associations, organized and operated in compliance with the requirements of section 521 and §1.521-1, shall be subject to the taxes imposed by section 11 or section 1201. Although such

(a) In general. For purposes of section 6049, a payor (as defined in §1.6049-4(a)(2)) of original issue discount (OID) on a tax-exempt obligation (as defined in section 1288(b)(2)) is required to report the daily portions of OID on the obligation as if the daily portions of OID that accrued during a calendar year were paid to the