(a) Imputed underpayment based on partnership adjustments—(1) In general. In the case of any partnership adjustments (as defined in §301.6241-1(a)(6)) by the Internal Revenue Service (IRS), if the adjustments result in an imputed underpayment (as determined in accordance with paragraph (b

includible in the transferor's gross income as ordinary income under section 617(d)(1), 1245(a), 1250(a), 1252(a), 1254(a), or 1255(a), whichever is applicable, if at the time of the transfer the U.S. person had sold the property at its fair market value. Recapture of depreciation under this paragraph (a) is required regardless of whether the exception to section 367(a)(1) provided by §1.367(a)-2(a

on account of the transmission of such obligations by the decedent's death is required to be reported as income in the return of the decedent for the year of his death. See §1.691(e)-1 for special provisions relating to the filing of an election to have the provisions of section 691(a)(4) apply in the case of installment obligations in respect of which section 44(d) of the Internal Revenue

retained, see paragraph (e) of §1.6001-1. (b) Records to be provided. Except as otherwise provided in paragraph (c) of this section, the requirements of section 6001 and section 964(c) for record keeping shall be considered satisfied if the books or records produced are sufficient to verify for the taxable year—

(a) Unless the distribution is one in respect of which information is required to be filed pursuant to §1.332-6(b), §1.368-3(a), or §1.1081-11, every corporation making

, see §301.6212-2 of this chapter. (d) Penalties. See sections 6651 and 6652(c) for failure to file a return or failure to pay the amount shown as tax on the return. (e) Coordination with

(a) Notice group. Section 6223(e)(1)(B)(ii) applies with respect to a notice group only if the request for notice described in §301.6223(b)-1 is received by the Internal Revenue Service at least 30 days before the notice is mailed to the tax matters partner. (b)

§37.141 of this part, each entity shall submit its initial plan for compliance with the complementary paratransit service provision by January 26, 1992, to the appropriate location identified in paragraph (f) of this section. (c) Annual Updates. Except as provided in this paragraph, each entity shall submit an annual update to its plan on January 26 of each

remittance, for the period September 16-26, no later than September 29. The brewer shall file a return on TTB F 5000.24, and make remittance, for the period September 27-30, no later than October 14. (2) Taxpayment not by electronic fund transfer. In the case of taxes for which remittance by electronic fund transfer (EFT) is not required by

make remittance, for the period September 16-26, no later than September 29. The manufacturer shall file a return on TTB F 5000.24, and make remittance, for the period September 27-30, no later than October 14. (2) Taxpayment not by electronic fund transfer. In the case of taxes for which remittance by electronic fund transfer (EFT) is not required by

section 664(d) of title 26. (3) Charitable gift annuityThe term "charitable gift annuity" has the meaning given it in section 501(m)(5) of title 26. (4) Final determinationThe term "final determination" includes an Internal Revenue Service determination, after exhaustion of donor's and

(a) General rule. A foreign corporation satisfies the stock ownership test of §1.883-1(c)(2) if more than 50 percent of the value of its outstanding shares is owned, or treated as owned by applying the attribution rules of paragraph (c) of this section, for at least half of the number of days in the foreign corporation's taxable

amounts, and whether paid in a single sum or otherwise), such annuity elements shall be considered to comprise a single contract for the purpose of the application of section 72 and the regulations thereunder. For rules relating to the allocation of investment in the contract in the case of annuity elements payable to two or more persons, see paragraph (b) of §1.72-6. (3

Reliance on the invalidity of a regulation. A taxpayer may not rely on an opinion or advice that a regulation is invalid to establish that the taxpayer acted with reasonable cause and good faith unless the taxpayer adequately disclosed, in accordance with §1.6662-3(c)(2), the position that the regulation in question is invalid. (2)

time, but referred to in this section as Letter 950-G), inviting the donor to file a formal protest and to request consideration by the appropriate IRS Appeals office. See §§601.105 and 601.106 of this chapter. Subsequently, the donor will be sent a notice of determination of value (Letter 3569, or such other document as may be utilized from time to time by the IRS for this purpose in cases where no

(a) Purpose and scope. This section provides a temporary regulation that, if and when adopted as a final regulation will be added as new paragraphs (c)(2)(iii)(B), (k), (n) and (q) of §1.897-1. Paragraph (b) of this section would then appear as paragraph (c)(2)(iii)(B) of

determined as of the date of the sale or exchange. (b) Applicable Federal rate. Except as otherwise provided in this section, the applicable Federal rate for a debt instrument is based on the term of the instrument (i.e., short-term, mid-term, or long-term). See section 1274(d)(1). The Internal Revenue Service publishes the applicable Federal rates for each month in the Internal Revenue Bulletin (see

basis under this section, items of income, gain, loss, deduction, and credit are assigned to each short taxable year on the basis of the corporation's normal method of accounting as determined under section 446. See, however, §1.1502-76(b)(1)(ii)(A)(2) for special rules for an S election that terminates under section 1362(d) immediately before the S corporation

designated on the prescribed form or in its instructions on or before February 28 (March 31 if filed electronically) of the year following the calendar year in which the reportable policy sale occurred. However, see §1.6050Y-1(b)(5) for transition rules. (d) Requirement of and time for furnishing statements—(1)

the return filed by the taxpayer for purposes of determining the amount of the addition to tax under sections 6651(a)(2) and (3). (4) Deficiency procedures. For deficiency procedures in the case of income, estate, and gift taxes, see sections 6211 through 6216, inclusive, and §§301.6211-1 through 301.6215-1, inclusive.

consideration is given to— (i) Whether the filer has incurred any penalty under §§301.6721-1, 301.6722-1, or 301.6723-1 in prior years for the failure (or under parallel provisions of prior law), and (ii) If the filer has incurred any such penalty in prior years, the extent of the filer's success in lessening its error rate from year

(a) Interim rules. The principles of paragraph (g) of §1.909-6 apply to taxable years beginning on or after January 1, 2011. (b) Effective/applicability date. This section applies to taxable years ending after February 9, 2015. See 26 CFR 1.909-4T (revised as

officer is authorized to use all necessary force to gain entry. (26 U.S.C. 5203)

chapter covers the requirements for obtaining a basic permit under the Federal Alcohol Administration Act. (26 U.S.C. 5171)

National Revenue Center. (26 U.S.C. 5173)

records specified for dealers in part 31 of this chapter. (26 U.S.C. 5121, 5122, 5124)

that alcoholic flavoring materials be gauged by the methods provided in part 30 of this chapter. (26 U.S.C. 5204, 5559)