monument H–9; south 26 degrees 40 minutes, east 51.0 feet to park monument H–10; south 32 degrees 40 minutes, east 340.0 feet to park monument H–11; south 11 degrees 35 minutes, east 190.0 feet to park monument H–12; south 41 degrees 26 minutes, east 329.0 feet to park monument H–13; thence crossing Pass Run south 57 degrees 00 minutes 36 seconds, west 1,871.32 feet to a marked white oak tree near the northeast edge of the fire road on top of Piney Mountain, thence north 58 degrees 36 minutes, west

TFA means section 1405(b) of the Taxpayer First Act (TFA), Public Law 116–25, 133 Stat. 981 (July 1, 2019) (codified at 26 U.S.C. 7623(d)).

://www.govinfo.gov/link/uscode/29/1135\" class=\"usc external\" target=\"_blank\" rel=\"noopener noreferrer\"\u003e1135\u003c/a\u003e, \u003ca href=\"https://www.govinfo.gov/link/uscode/26/410\" class=\"usc external\" target=\"_blank\" rel=\"noopener noreferrer\"\u003e26 U.S.C. 410\u003c/a\u003e, \u003ca href=\"https://www.govinfo.gov/link/uscode/26/411\" class=\"usc external\" target=\"_blank\" rel=\"noopener noreferrer\"\u003e411\u003c/a\u003e, \u003ca href=\"https://www.govinfo.gov/link/uscode/26/413\" class

external\" target=\"_blank\" rel=\"noopener noreferrer\"\u003e1060\u003c/a\u003e, \u003ca href=\"https://www.govinfo.gov/link/uscode/29/1135\" class=\"usc external\" target=\"_blank\" rel=\"noopener noreferrer\"\u003e1135\u003c/a\u003e, \u003ca href=\"https://www.govinfo.gov/link/uscode/26/410\" class=\"usc external\" target=\"_blank\" rel=\"noopener noreferrer\"\u003e26 U.S.C. 410\u003c/a\u003e, \u003ca href=\"https://www.govinfo.gov/link/uscode/26/411\" class=\"usc external\" target=\"_blank\" rel

\u003c/a\u003e, \u003ca href=\"https://www.govinfo.gov/link/uscode/29/1060\" class=\"usc external\" target=\"_blank\" rel=\"noopener noreferrer\"\u003e1060\u003c/a\u003e, \u003ca href=\"https://www.govinfo.gov/link/uscode/29/1135\" class=\"usc external\" target=\"_blank\" rel=\"noopener noreferrer\"\u003e1135\u003c/a\u003e, \u003ca href=\"https://www.govinfo.gov/link/uscode/26/410\" class=\"usc external\" target=\"_blank\" rel=\"noopener noreferrer\"\u003e26 U.S.C. 410\u003c/a\u003e, \u003ca href

(a) In generalIn the case of a sale of export property to a DISC by a person described in section 482, the taxable income of such DISC and such person shall be based upon a transfer price which would allow such DISC to derive taxable income attributable to such sale (regardless of the sales price actually charged) in an amount which

limited prescribed situations, a Government Transportation Request (GTR). See the “U.S. Government Passenger Transportation Handbook,” available at https://www.gsa.gov/transaudits. [65 FR 24569, Apr. 26, 2000, as amended at

adjustment to which this section applies, and the assets of the partnership constitute a trade or business (as described in §1.1060-1(b)(2)), then the partnership is required to use the residual method to assign values to the partnership's section 197 intangibles. To do so, the partnership must, first, determine the value of partnership assets other than section 197 intangibles under paragraph (a)(3) of

section 542 and §1.542-1, the character of the amount includible in gross income of such domestic corporation under this paragraph shall be determined as if such amount were realized directly by such corporation from the source from which it is realized by the controlled foreign corporation. See paragraph (a) of

, the holding period of an element shall be determined under section 1223, applied by treating the element as a separate property. However, for the purpose of determining applicable percentage, the holding period for an element shall, except to the extent provided in paragraphs (c)(5), (e), and (f) of this section, be determined in accordance with the rules prescribed in §1.1250-4.

return year regardless of whether one or more subsidiaries later cease to be members of the group, whether the group files a consolidated return for any subsequent year, whether the agent ceases to be the agent or a member of the group in any subsequent year, or whether the group continues pursuant to §1.1502-75(d) with a new common parent in any subsequent year. (3

-powered highway vehicle means a highway vehicle, as defined in §48.4061(a)-1(d), that is propelled by a diesel-powered engine. Diesel-powered train means any diesel-powered equipment or machinery that rides on rails. Thus, for example, the term includes a locomotive, work train, switching engine, and track

(a) Introduction—(1) In general. For purposes of determining whether an accrual basis taxpayer can treat the amount of any liability (as defined in §1.446-1(c)(1)(ii)(B)) as incurred, the all events test is not treated as met any earlier than the taxable year in which economic performance

members thereof intend to operate only in furtherance of one or more exempt purposes. (v) Unless otherwise prescribed by applicable regulations or other guidance published in the Internal Revenue Bulletin, an organization must, in order to establish its exemption, submit a detailed statement of its proposed activities with and as a part of its application for exemption (see

This section lists the table of contents for §§1.1471-1 through 1.1474-7 and §301.1474-1 of this chapter.