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72 FR 54544, Sept. 26, 2007. § 10.29 Conflicting interests. (a) Except as provided by paragraph (b) of this section, a practitioner shall not represent a client before the Internal Revenue
(a) Qualified appraisal—(1) Definition. For purposes of section 170(f)(11) and §1.170A-16(d)(1)(ii) and (e)(1)(ii), the term qualified appraisal means an appraisal document that is prepared by a qualified appraiser (as defined in paragraph (b)(1) of
Refunds includible in gross income. If any portion of the contested amount which is deducted under subparagraph (1) of this paragraph for the taxable year of transfer is refunded when the contest is settled, such portion is includible in gross income except as provided in §1.111-1, relating to recovery of certain items previously deducted or credited. Such refunded amount is includible
). See section 316 and §1.316-2 for provisions relating to the allocation of earnings and profits among distributions. (2) Previously taxed income. This paragraph (d)(2) applies to distributions by a corporation that has both accumulated earnings and profits and previously taxed income (within the meaning of section 1375(d)(2), as
If in a liquidation completed within one taxable year pursuant to a plan of complete liquidation, distributions in complete liquidation are received by a corporation which owns the specified amount of stock in the liquidating corporation and which continues qualified with respect to the ownership of such stock until the transfer of all the property within such year is completed (see paragraph (a) of
(a) The regulations under section 383 (other than the regulations described in paragraph (b) of this section) reflect the amendments made to sections 382 and 383 by the Tax Reform Act of 1986. See §1.383-1(j) for effective date rules. (b) Sections 1.383-1A, 1.383-2A, and 1.383-3A do not reflect the amendments made to sections 382 and 383
An estate or trust is allowed a credit against the tax for dividends received on or before December 31, 1964 (see section 34), only for so much of the dividends as are not properly allocable to any beneficiary under section 652 or 662. Section 642(a)(3), and this section do not apply to amounts received as dividends after December 31, 1964. For treatment of the credit in the hands of the beneficiary see
Sections 1.815-2 through 1.815-6, except as otherwise provided therein, are applicable only to taxable years beginning after December 31, 1957, and all references to sections of part I, subchapter L, chapter 1 of the Code are to the Internal Revenue Code of 1954, as amended by the Life Insurance Company Income Tax Act of 1959 (73 Stat. 112), the Act of October 10
Sections 1.960-1 through 1.960-6 apply to each taxable year of a foreign corporation that both begin after December 31, 2017, and ends on or after December 4, 2018, and to each taxable year of a domestic corporation that is a United States shareholder of the foreign corporation in which or with which such taxable year of such foreign corporation ends.
For purposes of section 989(b)(3) and (4), the term “weighted average exchange rate” means the simple average of the daily exchange rates (determined by reference to a qualified source of exchange rates described in §1.988-1(d)(1)), excluding weekends, holidays and any other nonbusiness days for the taxable year. [T.D
(a) In general. For general definitions regarding section 6694 penalties applicable to preparers of estate tax returns or claims for refund, see §1.6694-1 of this chapter. (b) Effective/applicability date. Paragraph (a) of this section is applicable to returns
(a) In general. For general definitions regarding section 6694 penalties applicable to preparers of gift tax returns or claims for refund, see §1.6694-1 of this chapter. (b) Effective/applicability date. Paragraph (a) of this section is applicable to returns
(a) In general. For general definitions regarding section 6694 penalties applicable to preparers of generation-skipping transfer tax returns or claims for refund, see §1.6694-1 of this chapter. (b) Effective/applicability date. Paragraph (a) of this section is
(a) In general. For general definitions regarding section 6694 penalties applicable to preparers of returns or claims for refund of any tax to which this part 40 applies, see §1.6694-1 of this chapter. (b) Effective/applicability date. This section is
(a) In general. For rules for claims for credit or refund by a tax return preparer who prepared a return or claim for refund for excise tax under section 4481, the rules under §1.6696-1 of this chapter will apply. (b) Effective/applicability date. This section
, correct, and correction period, see §53.4963-1.
(a) In general. For general definitions regarding section 6694 penalties applicable to preparers of tax returns or claims for refund under Chapter 42 of the Internal Revenue Code, see §1.6694-1 of this chapter. (b) Effective/applicability date. Paragraph (a
(a) In general. For general definitions regarding section 6694 penalties applicable to preparers of tax returns or claims for refund of tax under Chapter 43 of subtitle D, see §1.6694-1 of this chapter. (b) Effective/applicability date. Paragraph (a) of this
(a) In general. For general definitions regarding section 6694 penalties applicable to preparers of tax returns or claims for refund of tax under chapter 44 of Subtitle D see §1.6694-1 of this chapter. (b) Effective/applicability date. Paragraph (a) of this
(a) In general. For general definitions regarding section 6694 penalties applicable to preparers of tax returns or claims for refund of tax under chapter 41 of subtitle D see §1.6694-1 of this chapter. (b) Effective/applicability date. Paragraph (a) of this
(a) In general. For general definitions regarding section 6694 penalties applicable to preparers of tax returns or claims for refund for tax under section 5881 of the Internal Revenue Code, see §1.6694-1 of this chapter. (b) Effective/applicability date.
(a) In general. For general definitions regarding section 6694 penalties applicable to preparers of tax returns or claims for refund for tax under section 5891 of the Internal Revenue Code see §1.6694-1 of this chapter. (b) Effective/applicability date.
(a) In general. For provisions relating to the requirement of the disclosure by a tax-exempt entity that it is a party to certain reportable transactions, see §1.6033-5 of this chapter (Income Tax Regulations). (b) Effective date/applicability date. This
For taxable years beginning after October 16, 1962, the term “cooperative bank” means an institution without capital stock organized and operated for mutual purposes without profit which meets the supervisory test, the business operations test, and the various assets tests specified in paragraphs (d) through (h) of §301.7701-13, employing the rules and definitions of paragraphs (j) through
surface winds for which approval is desired. [Amdt. 29-3, 33 FR 967, Jan. 26, 1968, as amended by Amdt. 27-26, 55 FR 8003, Mar. 6, 1990]
Federal Register. [61 FR 67945, Dec. 26, 1996, as amended at 81 FR 33391, May 26, 2016]
Codification R.S. §4813 derived from act Feb. 26, 1811, ch. 26, §5, 2 Stat. 650.
[26 FR 8196, Aug. 31, 1961. Redesignated at 40 FR 16835, Apr. 15, 1975, and further redesignated and amended by T.D. TTB-16, 69 FR 52424, 52425, Aug. 26, 2004]