be made independently of, and without reference to, the modifications required by §§1.172-2(a) and 1.172-3(a) for purposes of computing the net operating loss itself. (1) Modifications applicable to unincorporated taxpayers only. In the case of a taxpayer other than a corporation, in computing taxable income and adjusted

(a) Definition of intercompany profit amount. For purposes of this section, the term “intercompany profit amount” for a taxable year means an amount equal to the profits of a corporation (other than those profits which such corporation has elected not to defer pursuant to §1.1502- 13(c)(3) or which have been taken into account pursuant to

(b) Definitions. For purposes of this section, the following definitions apply: (1) Amount paid. In the case of a taxpayer using an accrual method of accounting, the terms amounts paid and payment mean a liability incurred (within the meaning of

sections 18032(f)(3), 18071(e), and 18082(d) of this title and section 36B(e) of title 26 that the individual be a citizen or national of the United States or an alien lawfully present in the United States; (2) in the case of an individual claiming a premium tax credit or reduced cost-sharing under

(b) Acceleration events—(1) Deferred COD income. Except as otherwise provided in paragraphs (b)(2) and (3) of this section, and §1.108(i)-2(b)(6) (in the case of a corporate partner), an electing corporation's deferred COD income is taken into account ratably over the inclusion period.

(a) Export trade corporations—(1) In general. For purposes of sections 970 through 972 and §§1.970-1 to 1.972-1, inclusive, the term “export trade corporation” means a controlled foreign corporation which for the period specified in subparagraph (2) of this paragraph satisfies the conditions

months but less than twelve months. Except as otherwise provided, in the case of a short taxable year, if such year results in a taxable year of four or more full calendar months but less than twelve full calendar months, the due dates prescribed in §1.6655-1(f)(2) apply. (ii) Exceptions.

paid or incurred by an S corporation is made by the S corporation. In the case of qualified capital costs paid or incurred by the members of a consolidated group (within the meaning of §1.1502-1(h)), the section 179B election with respect to such costs is made for each member by the common parent of the group. (B)

(a) General rule. The term taxable income from the property (computed without allowance for depletion), as used in section 613 and this part, means gross income from the property as defined in section 613(c) and §§1.613-3 and 1.613-4, less all allowable

This section lists the headings for §§1.951A-1 through 1.951A-7. §1.951A-1   General provisions. (a) Overview. (1) In general. (2

(b) Requirements—(1) In general. A party has not exhausted the administrative remedies available within the Internal Revenue Service with respect to any tax matter for which an Appeals office conference is available under §§601.105 and 601.106 of this chapter (other than a tax matter described

Notice. A deposition must not be used against a party who, having received less than 14 days' notice of the deposition, promptly moved for a protective order under Rule 26(c)(1)(B) requesting that it not be taken or be taken at a different time or place—and this motion was still pending when the deposition was taken. (B) Unavailable Deponent; Party Could Not

20 U.S.C. 1001); and "(7) the term 'nonprofit organization' means an organization described in section 501(c)(3)of [sic] the Internal Revenue Code of 1986 [26 U.S.C. 501(c)(3)] and exempt from taxation under

N. Vermont Executive Order Submitted for Incorporation Into the SIP III. Proposed Action IV. Incorporation by Reference

Not later than 1 year after July 26, 1990, the Secretary of Transportation shall issue regulations, in an accessible format, necessary for carrying out this subpart. Effective Date Section effective July 26, 1990, see

(a) [Reserved] (b) Publicly traded partnership—(1) In general. For purposes of section 469(k), a partnership is a publicly traded partnership only if the partnership is a publicly traded partnership as defined in §1.7704-1. (2

in a court other than the Tax Court, see paragraph (b) of §1.533-1.

A personal holding company which files or is required to file a consolidated return with other members of an affiliated group may be required to file a separate personal holding company schedule by reason of the limitations and exceptions provided in section 542(b) and §1.542-4. Section 562(d) provides that in such case the dividends paid deduction shall be allowed to the personal holding

Section 1031(c) provides that a loss shall not be recognized from an exchange of property described in section 1031(a), 1035(a), 1036(a), or 1037(a) where there is received in the exchange other property or money in addition to property permitted to be received without recognition of gain or loss. See example (4) of paragraph (a)(3) of §1.1037-1 for an illustration

Stripped inflation-protected debt instruments. If a Treasury Inflation-Protected Security is stripped under the Department of the Treasury's Separate Trading of Registered Interest and Principal of Securities (STRIPS) program, the holders of the principal and coupon components must use the discount bond method (as described in

(a) Reliance. If the valuation date is after April 30, 1989, and before June 10, 1994, a taxpayer can rely on Notice 89-24, 1989-1 C.B. 660, or Notice 89-60, 1989-1 C.B. 700 (See §601.601(d)(2)(ii)(b) of this chapter), in valuing the transferred interest. (b

Under section 2056A(b)(13), in the case of any distribution from a QDOT on which an estate tax is imposed under section 2056A(b)(1)(A), the distribution is treated as a transfer by gift for purposes of section 1015, and any estate tax paid under section 2056A(b)(1)(A) is treated as a gift tax. See §1.1015-5(c)(4) and (5) of this chapter for rules for determining the

Section 25.2703-1 applies to any right or restriction created or substantially modified after October 8, 1990, and is effective as of January 28, 1992. With respect to transfers occurring prior to January 28, 1992, and for purposes of determining whether an event occurring prior to January 28, 1992 constitutes a substantial modification, taxpayers may rely on any

month there are combatant activities in some combat zone (as determined under section 112). See §1.112-1 of this chapter (Income Tax Regulations).

(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 employment tax under chapters 21 through 25 of subtitle C of the Internal Revenue Code, the rules under §1.6696-1 of this chapter will apply. (b)

(a) In general. The rules under §1.6696-1 of this chapter will apply for claims for credit or refund by a tax return preparer who prepared a return or claim for refund of any tax to which this part 40 applies. (b) Effective/applicability date. This section is

(a) In general. A person who is a tax return preparer of any return or claim for refund of excise tax under section 4481 shall be subject to penalties under section 6694(a) in the manner stated in §1.6694-2 of this chapter. (b) Effective/applicability date.

(a) In general. A person who is a tax return preparer of any return or claim for refund of excise tax under section 4481 shall be subject to penalties under section 6694(b) in the manner stated in §1.6694-3 of this chapter. (b) Effective/applicability date.