(a) General ruleIn the case of a taxpayer (other than a bank as defined in section 581) no deduction shall be allowed under section 166 (relating to bad debts) or under

(a) Allocation in case of reinsurance agreement involving tax avoidance or evasionIn the case of 2 or more related persons (within the meaning of section 482) who are parties to a reinsurance agreement (or where one of the parties to a reinsurance agreement is, with respect to any contract covered by the agreement, in effect an agent

items entering into the computation of distributable net income of the estate or trust as the total of each class bears to the total distributable net income of the estate or trust in the absence of the allocation of different classes of income under the specific terms of the governing instrument. In the application of the preceding sentence, the items of deduction entering into the computation of distributable net income (including the deduction allowed under

shall have jurisdiction of any action brought by the United States to quiet title to property if the title claimed by the United States to such property was derived from enforcement of a lien under this title. (f) General jurisdictionFor general jurisdiction of the district courts of the United States in civil actions involving internal revenue, see section

(a) shall include a finding of the correct amount which should have been reported in the information return. (f) Information returnFor purposes of this section, the term "information return" means any statement described in section 6724(d)(1)(A).

section shall be payable out of funds appropriated under section 1304 of title 31, United States Code. (d) Period for bringing actionNotwithstanding any other provision of law, an action to enforce liability created under this section may be brought without regard to the amount in controversy and may be brought only within 2 years after the date the

[56 FR 12457, Mar. 26, 1991] {"origins":[{"level":"part","identifier":"101-26","label_level":"Part 101-26","hierarchy":{"title":"41","subtitle":"C","chapter":"101","subchapter":"E","part":"101-26"},"current":false,"authority":["\u003ca href=\"https://www.govinfo.gov/link/uscode/40/121

years after the disposition of the share or carryover basis asset, and (iii) If the disposition is of a share of subsidiary stock, it is not a transfer to which §1.1502-36 applies. (b) Redetermination of basis on certain nondeconsolidating transfers of subsidiary stock and on certain

sections 402 and 6652 of Title 26, Internal Revenue Code] shall apply to distributions after December 31, 1984. "(d) Special Rules for Treatment of Plan Amendments.— "(1) In general.—Except as provided in paragraph (2), the amendments made by

ADDRESSES: Comments should be sent to both agencies at the addresses listed below. CFTC: You may submit comments, identified by RIN 3038-AF07, by any of the following methods: CFTC website: https://comments.cftc.gov. Follow the instructions for submitting comments through the website.