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used a dwelling unit for personal purposes for a day if, for any part of such day, the unit is used— (A) for personal purposes by the taxpayer or any other person who has an interest in such unit, or by any member of the family (as defined in section 267(c)(4)) of the taxpayer or such other person; (B) by any individual who uses
, (D) a victim of tax-related identity theft, (E) a taxpayer substantially all of whose income consists of disability insurance benefits under section 223 of the Social Security Act or supplemental security income benefits under title XVI of the Social Security Act (including supplemental security income benefits of the type
from a modification of the debt instrument), the exchange of the debt instrument for corporate stock or a partnership interest, the contribution of the debt instrument to capital, the complete forgiveness of the indebtedness by the holder of the debt instrument, and a direct or an indirect acquisition within the meaning of §1.108-2. (2)
(b) Determining properly allocable or apportioned deductions. The amount of deductions properly allocable or apportioned to gross income or stock described in paragraphs (a)(1)(ii) and (iii) of this section is determined by subdividing the United States shareholder's gross income and assets in each separate category described in §1.904-5(a)(4)(v) into a
The following list contains the major headings in §§1.1502-91 through 1.1502-99: §1.1502-91   Application of section 382 with respect to a consolidated
its employee, except where taxes were not withheld from the employee or where, after reasonable efforts, the employer cannot locate the employee. Every adjusted return shall designate the return period in which the error was ascertained and the return period being corrected, explain in detail the grounds and facts relied upon to support the correction, and set forth such other information as may be required by this section and
(a) In general. Except as provided in section 6235(c), section 905(c), or paragraph (d) of this section (regarding extensions), no partnership adjustment (as defined in §301.6241-1(a)(6)) for any partnership taxable year may be made after the later of the date that is— (1) 3 years after the
treatment under paragraph (1)(A). (B) Affiliate definedFor purposes of this paragraph, the term "affiliate" has the meaning given such term by section 117(a)(4) of the Federal Alcohol Administration Act (27 U.S.C. 211(a)(4)) and includes a winery's
This section lists the table of contents for §§1.468B-1 through 1.468B-9. §1.468B-1   Qualified settlement funds. (a) In general. (b
(a) In general. Except as provided in this section, the rules contained in §§1.904(f)-1, 1.904(f)-2, 1.904(f)-3, 1.904(f)-4, and 1.904(f)-6 apply to domestic trusts. (b) Recapture of trust's overall foreign loss. In taxable years in which a trust has
(a) Married couples with two qualified individuals—(1) In general. In the case in which a husband and wife both are qualified individuals under §1.911-2(a), each individual may make one or more elections under
(a) Shareholder adjustment for previously taxed income. (1) Under section 996(d)(1), except as provided in subparagraph (2) of this paragraph, if— (i) Gain with respect to a share of stock of a DISC, or former DISC, is treated under §1.995-4 as a dividend, and
(a) Requirement. Every person filing (1) a Form 1099 or 1087 under section 6049(a)(1) and §1.6049-1 with respect to payments of interest or (2) a Form 1099-OID or 1087-OID with respect to original issue discount includible in gross income, shall furnish to the person whose identifying number is (or should be) shown on the form a
Prior Provisions A prior section 1378, added Pub. L. 89–389, §2(a), Apr. 14, 1966, 80 Stat. 113; amended
No tax shall be imposed by section 4051 on any of the following articles: (1) Camper coaches bodies for self-propelled mobile homesAny article designed— (A) to be mounted or placed on automobile trucks, automobile truck chassis, or automobile chassis, and
manager who refused to agree to part or all of the removal from jeopardy. (c) Exception for program-related investmentsFor purposes of this section, investments, the primary purpose of which is to accomplish one or more of the purposes described in section 170(c)(2)(B), and no significant purpose of which is the production of income or the appreciation of
administration and collection costs involved would not warrant collection of the amount due. (d) Assessments attributable to certain mathematical errors by Internal Revenue ServiceIn the case of an assessment of any tax imposed by chapter 1 attributable in whole or in part to a mathematical error described in section 6213(g)(2)(A), if the return was prepared by
(a) Payments pursuant to hybrid transactions—(1) In general. If a specified payment is made pursuant to a hybrid transaction, then, subject to §1.267A-3(b) (amounts included or includible in income), the payment is a disqualified hybrid amount to the extent that—
generalExcept as provided in subparagraph (B), the Federal short-term rate determined under paragraph (1) for any month shall apply during the first calendar quarter beginning after such month. (B) Special rule for individual estimated taxIn determining the addition to tax under section 6654 for failure to pay estimated tax for any taxable
(a) Surviving spouse's estate limited to DSUE amount of last deceased spouse—(1) In general. The deceased spousal unused exclusion (DSUE) amount of a decedent, computed under §20.2010-2(c), is included in determining the surviving spouse's applicable exclusion amount under section 2010(c)(2
(a) Introduction—(1) Section 4943 (c)(4) in general. (i) Paragraph (4) of section 4943(c) prescribes transition rules for a private foundation which, but for such paragraph, would have excess business holdings on May 26, 1969. Section 4943(c)(4) provides such a foundation with protection from the initial tax on excess business holdings in two ways. First
This section lists the captions contained in §§1.43-0 through 1.43-7. §1.43-1   The enhanced oil recovery credit—general rules. (a) Claiming the credit. (1) In general. (2) Examples. (b) Amount of the
§1.907(c)-3. (c) FOGEI tax limitation. Section 907(a) limits the foreign tax credit for taxes paid or accrued on FOGEI. See §1.907(a)-1. (d) Reduction of
(a) The amount of the Federal estate tax attributable to the transferred property in the transferor's estate is the “first limitation.” Thus, the credit is limited to an amount, A, which bears the same ratio to B (the “transferor's adjusted Federal estate tax”, computed as described in paragraph (b) of this section) as C (the value of the property transferred (see
(a) General. Section 5051(a)(2) of Title 26 U.S.C. provides for a reduced rate of tax on the first 60,000 barrels of beer removed for consumption or sale by a brewer during a calendar year. To be eligible to pay the reduced rate of tax, a brewer: (1) Shall brew or produce the beer at a qualified brewery in the United States; (2) May not produce more than
(2) as a guaranteed payment described in section 707(c) if the amount thereof is determined without regard to the income of the partnership. (b) Payments for interest in partnership (1) General rulePayments made in liquidation of the interest of a retiring partner or a deceased partner shall, to the
property, of whatever nature, of the delinquent, or in which he has any right, title, or interest, to the payment of such tax or liability. For purposes of the preceding sentence, any acceleration of payment under section 6166(g) shall be treated as a neglect to pay tax. (b) PartiesAll persons having liens upon or claiming any interest in the property