§§20.6166-1 through 20.6166-3 is available also in cases where the due date of the return is before September 3, 1958, but under somewhat different circumstances. These differences are explained in paragraphs (b) through (e) of this section. Therefore except as otherwise provided in paragraphs (b) through (e) of this section, the regulations contained in

(a) Portion defined. Except as provided in paragraph (b) of this section and §301.7701(i)-1, a portion of an entity includes all assets that support one or more of the same issues of debt obligations. For this purpose, an asset supports a debt obligation if, under the terms of the debt obligation (or underlying

(a) As used in §§521.101 to 521.117, unless the context otherwise requires, the terms defined in the convention shall have the meanings so assigned to them. Any term used in §§521.101 to 521.117, which is not defined in the convention but which is defined in the Internal

. United States person as defined in 26 U.S.C. 7701(a)(30) means— (1) A citizen or resident of the United States; (2) A domestic partnership; (3) A domestic corporation; (4) Any estate (other than a foreign estate, within the meaning of 26 U.S.C. 701(a)(31)); and (5) Any trust if— (i) A court within the United States is able to exercise primary supervision over the administration of the trust; and (ii

Internal Revenue Code of 1986, as amended (codified in 26 U.S.C.). Levy. The taking of property by seizure and sale or by collection of money due to the debtor, such as wages. Lien. A charge upon real or personal property for the satisfaction of some debt or performance of an obligation. Person

created condition, and (3) the lessor's interest in the land is primarily a security interest to protect the rental payments to which the lessor is entitled under the lease. (d) Cross referenceFor treatment of rentals under redeemable ground rents as interest, see section 163(c).

use of obscene or profane language or language the natural consequence of which is to abuse the hearer or reader. (3) Causing a telephone to ring or engaging any person in telephone conversation repeatedly or continuously with intent to annoy, abuse, or harass any person at the called number. (4) Except as provided under rules similar to the rules in

certification remains effective for an additional period extending until the completion of the re-certification process by the Attorney General and any related judicial review. {"origins":[{"level":"part","identifier":"26","label_level":"Part 26","hierarchy":{"title":"28","chapter":"I","part":"26"},"current":false,"authority":["\u003ca href=\"https://www.govinfo.gov/link/uscode/5/301\" class=\"usc external\" target=\"_blank\" rel

§1.367(b)-2(a)) immediately before or immediately after the triangular reorganization; (ii) S is a domestic corporation, P's stock in S is not a United States real property interest (within the meaning of section 897(c)), and P would not be subject to U.S. tax on a dividend (as determined under section 301(c)(1)) from S under either section 881 (for example, by reason of an

(a) Exception for gifts—(1) General rule. In general, no gain shall be recognized under section 1255(a)(1) upon a disposition of section 126 property by gift. For purposes of section 1255 and this paragraph, the term “gift” shall have the same meaning as in §1.1245-4(a) and, with respect to

This section lists the captions that appear in the regulations under section 469. §1.469-1   General rules. (a)-(c)(7) [Reserved] (c) (8) Consolidated groups. (c) (9)-(d)(1) [Reserved] (2) Coordination with sections

) Termination as life insurance company—(1) Effect of termination. Except as provided in section 381(c)(22) (relating to carryovers in certain corporate readjustments), section 815(d)(2)(A) provides that if for any taxable year the taxpayer is not an insurance company (as defined in paragraph (a) of §1.801-3), or if for any

instrument is the amount paid for the instrument. For example, in the case of a debt instrument evidencing a loan to a natural person, the issue price of the instrument is the amount loaned. See §1.1275-2(d) for rules regarding Treasury securities. For purposes of this paragraph (a), money includes functional currency and, in certain circumstances, nonfunctional currency. See

apportion either a consolidated section 382 limitation or a subgroup section 382 limitation. (3) Coordination with §§1.1502-91A through 1.1502-93A. For rules regarding the determination of whether there is an ownership change of a loss subgroup and the computation of a subgroup section 382 limitation following such an ownership

) (prior to its amendment by the Act). When, in a taxable year after the effective date of the Act, earnings and profits attributable to such income are distributed to, or included in the gross income of, a United States shareholder under section 951(a)(1) (A) (ii) or (iii) or (B) (hereinafter in this section “inclusions”), the ordering rules of section 904(d)(3)(D) and §1.904-5(c)(4) shall be applied in

USDA will take action to effect administrative offset against tax refunds due to debtors under 26 U.S.C. 6402 in accordance with the provisions of 31 U.S.C. 3720A through referral for centralized administrative offset under

Section 5062(c), Internal Revenue Code, as amended (26 U.S.C. 5062(c)), provides for the refund, remission, abatement or credit to the importer of internal revenue taxes paid or determined incident to importation, upon the exportation, or destruction under CBP supervision, of imported distilled spirits, wines, or beer found after entry to be unmerchantable or not to conform to sample or

Section 5062(c), Internal Revenue Code, as amended (26 U.S.C. 5062(c)), provides for the refund, remission, abatement or credit to the importer of internal-revenue taxes paid or determined incident to importation, upon the exportation, or destruction under Customs supervision, of imported distilled spirits, wines, or beer found after entry to be unmerchantable or not to conform to sample or

Whenever TTB finds it is necessary to meet the requirements of national defense or necessary or desirable by reason of disaster, TTB may temporarily exempt the proprietor from any provisions of the internal revenue laws and the provisions of this part relating to distilled spirits, except those requiring the payment of tax. (

An applicant or proprietor of a distilled spirits plant must execute and submit to the appropriate TTB officer form TTB F 5000.8, Power of Attorney, for each person authorized to sign or to act on behalf of the applicant or proprietor unless the authority has been granted in the application for registration. (26 U.S.C. 5172

If the name of the proprietor changes, the proprietor must file a letterhead application to amend the operating permit. The proprietor may not conduct operations under the new name before TTB approves the amended operating permit. However, the proprietor does not have to file a new bond or consent of surety. (26 U.S.C. 5172

All pipelines, including flexible hoses, that are used to transfer spirits, denatured spirits, articles, and wines must be constructed, arranged, and secured so as to ensure protection of the revenue and permit ready examination. The appropriate TTB officer may approve pipelines that cannot be readily examined if they pose no jeopardy to the revenue. (

A proprietor may file a claim for credit of tax, as provided in this part, after the tax has been determined, whether or not the tax has been paid. However, a proprietor may not anticipate allowance of a credit or make an adjusting entry in a tax return pending action on the claim. (26 U.S.C. 5008, 5215)

When wines or spirits of less than 190° of proof are mingled in a tank, the proprietor must gauge the spirits or wines in the tank and record the mingling gauge on the tank record prescribed in §19.592. (26 U.S.C. 5201)

A proprietor may add oak chips that have not been treated with any chemical to packages of spirits. The proprietor must note the use of oak chips on all transaction records. A proprietor may add caramel that has no material sweetening properties to rum or brandy stored in packages or tanks. (26 U.S.C. 5201)

A proprietor must take a physical inventory of all wines and bulk spirits (except packages) held in the processing account at the close of each calendar quarter. The results of the inventory must be recorded as provided in subpart V of this part. TTB may require additional inventories at any time. (26 U.S.C. 5201)

A vinegar manufacturer qualified under this subpart may: (a) Separate by a vaporizing process the distilled spirits from a mash; and (b) Condense the distilled spirits vapors by introducing them into the water or other liquid to make the vinegar. (26 U.S.C. 5504