foreign oil related income to recapture the pre-1983 FORI limitation overall foreign loss account, and shall apply such rules to the taxpayer's separately determined general limitation income (exclusive of foreign oil related income) to recapture the pre-1983 general limitation overall foreign loss account (or the section 904(d)(1)(A-C) overall foreign loss account. Rules for determining the recapture of the pre-1983 section 904 (d)(1)(A-C) losses are contained in

a specified depth which was short of where the oil was expected to be found.[26] The Act would also apply to drilling operations even though no oil was discovered.[27] Laborers employed in erecting drilling rigs would also be covered.[

72 FR 54544, Sept. 26, 2007. § 10.22 Diligence as to accuracy. (a) In general. A practitioner must exercise due diligence— (1) In preparing or assisting in the preparation of, approving, and filing tax returns, documents, affidavits

educational institution requester, a non-commercial scientific institution requester, or a representative of the news media requester. (2) Commercial use request means a request from or on behalf of a person who seeks information for a use or purpose that furthers the requester's or other person's commercial

(2) Accessibility.—The direct link under paragraph (1) shall be obvious and facilitate accessibility to the website of the Office of the Inspector General. (b) Requirements for Inspectors General Websites.— (1) Posting of reports and audits.—The Inspector General of each Federal agency and designated Federal entity shall

the Director of the Office of Management and Budget; and (ii) the amount in controversy for any taxable year generally does not exceed the amount specified in section 7463. (2) ClinicThe term "clinic" includes— (A) a clinical program at an accredited law, business, or

of products no longer authorized for a particular formula may continue that use. Pursuant to written application and subject to the provisions of 26 U.S.C. Chapter 51, part 20 of this chapter, and this part, the appropriate TTB officer, may authorize the use of any formula of specially denatured alcohol or specially denatured rum for uses not specifically authorized in this part. The code number

(c) The fill tests and alcohol tests required by §24.255 for each lot of wine bottled or packed, or for each bottling or packing line operated each day, showing the date, type of test, item tested and the test results. (d) If a tax credit under 26 U.S.C. 5041(c) may

(a) By return, Form 5000.24. A brewer who is eligible to pay the reduced rate of tax on beer may, upon filing the notice required by §25.167, pay the reduced rate of tax on beer by return for deferred payment of tax as provided in §25.164

shall be available from the Expense Allowance an expense allotment not to exceed $6,000 for each of the above specified officers. Amounts paid from the expense allotment of any such officer shall be paid to him only as reimbursement for actual expenses incurred by him and upon certification and documentation by him of such expenses. Amounts paid to any such officer pursuant to this section shall not be reported as income and shall not be allowed as a deduction under title 26.

special taxes. (d) Cross references. For provisions relating to registration and information required to be reported on Form 11-C, see §44.4412-1. For other provisions relating to Form 11-C, see §§44.6011(a)-1 (relating to

Prior to each fiscal period, and as may be necessary thereafter the committee shall prepare a budget of estimated income and expenditures necessary for the administration of this part. The committee shall recommend to the Secretary a rate of assessment calculated to provide adequate funds to defray its proposed expenditures. The committee shall present such budget promptly to the Secretary with an accompanying report thereon showing the basis for its calculations

Dividends excluded from gross income under section 116 (relating to partial exclusion of dividends received) are included in distributable net income. For this purpose, adjustments similar to those required by §1.643(a)-5 with respect to expenses allocable to tax-exempt income and to income included in amounts paid or set aside for charitable purposes are not

Notwithstanding any other provision of law, the Tax Court may exercise, for purposes of management, administration, and expenditure of funds of the Court, the authorities provided for such purposes by any provision of law (including any limitation with respect to such provision of law) applicable to a court of the United States (as that term is defined in

For purposes of this subparagraph, the term "small employer" has the meaning given such term by section 4980D(d)(2) of title 26, except that such section shall be applied by substituting "500" for "50" each place it appears. (B) Benefit requirements (i) In general

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. (

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

A brewery may not be established or operated in any dwelling house or on board any vessel or boat, or in any building or on any premises where the revenue will be jeopardized or the effective administration of this part will be hindered. (Sec. 201, Pub. L. 85-859, 72 Stat. 1389, as amended (26 U.S.C. 5402))

A brewer may remove beer from the brewery, without payment of tax, by pipeline to the bonded premises of a distilled spirits plant which is authorized to produce distilled spirits and which is located contiguous to the brewery. (Sec. 201, Pub. L. 85-859, 72 Stat. 1365, as amended, 1389, as amended (26 U.S.C. 5222, 5412

The tax on imported beer shall be computed on the basis of the actual quantity in a container, at the rate prescribed by law. (72 Stat. 1333, as amended; 26 U.S.C. 5051) [T.D. 6644, 28 FR 3165. Apr. 2, 1963. Redesignated at 40 FR 16835, Apr. 15, 1975]

Where a number of persons who have filed a registration under this part as partners admit one or more new members to the partnership or form a corporation (a separate legal entity) to take over the business, the new partnership or corporation must register as a new dealer before commencing business. (26 U.S.C. 5121, 5122

When a wholesale dealer in liquors who is required, under §31.160, to file a monthly summary report discontinues business, a monthly summary report marked “Final” must be filed covering transactions through the date of discontinuance. (

Where there is any change in the officers or directors of a corporation operating the business of an export warehouse proprietor, the proprietor shall furnish to the appropriate TTB officer notice, in writing, of the election of the new officers or directors within 30 days after such election. (72 Stat. 1421; 26 U.S.C. 5712