related party) in respect of property, or borrowed money, used or to be used for a private business use. The private security portion of the test takes into account the payment of the debt service on the issue that is directly or indirectly secured by any interest in property used or to be used for a private business use or payments in respect of property used or to be used for a private business use. For additional rules for output facilities, see

§1.706-1(c)(2) and (3), or with respect to a partner whose interest in a partnership is reduced as described in §1.706-1(c)(3), including by the entry of a new partner (collectively, a “variation”). (2) Coordination with sections 706(d)(2) and 706(d)(3) and other Code sections. Items

sale. Example 5. A taxpayer owns two operating mineral interests in oil wells, designated Nos. 1 and 2, in tract A, and another such interest, designated No. 3, in tract B. All three interests are in the same operating unit (as defined in paragraph (c) of §1.614-2

that is a section 401(l) plan is a fraction— (i) The numerator of which is the disparity provided under the plan for the plan year, and (ii) The denominator of which is the maximum excess allowance under §1.401(l)-2(b)(2) for the plan year. (4) Annual

(a) In general. Subject to section 2056(d), a marital deduction is allowed under section 2056(b)(7) with respect to estates of decedents dying after December 31, 1981, for qualified terminable interest property as defined in paragraph (b) of this section. All of the property for which a deduction is allowed under this paragraph (a) is treated as passing to the surviving spouse (for purposes of

with any candidate, group of candidates, or political party. (5) Voter guides. (i) A corporation or labor organization may prepare and distribute to the general public voter guides, including voter guides obtained from a nonprofit organization that is described in

to the division and office descriptions, as discussed in detail below. A. Delegation to the Director and Chief Economist of the Division of Economic and Risk Analysis We are delegating authority to the Director of the Division of Economic and Risk Analysis (“DERA”) and Chief Economist to update taxonomies and schemas required for use in Commission filings and made available on the Commission's website.[3

Exception. The term “listed property” does not include any vehicle that is a qualified nonpersonal use vehicle as defined in section 274(i) and §1.274-5(k). (3) Property used for entertainment, etc.—(i) In general. Property of a type generally used for

encumbrances) immediately before the transfer. Fair market value shall be determined as of the time of the transfer. (ii) Notwithstanding subdivision (i) of this subparagraph, a transferee organization which is not effectively controlled (within the meaning of §1.482-1(a)(3)), directly or indirectly, by the same person or persons who effectively control the transferor

taken into account in computing the valuation of the property for customs purposes may not, for purposes of the basis or inventory cost, be greater than the amount of the costs used in computing the customs value. For purposes of this section, the terms controlled taxpayer and group of controlled taxpayers shall have the meaning set forth in

. The phrase “substantially separate and independent shares” generally has the same meaning as provided in §1.663(c)-3. However, except as provided in paragraph (a)(1)(iii) of this section, a portion of a trust is not a separate share unless such share exists from and at all times after the creation of the trust. For purposes of this paragraph (a)(1), a trust is treated as created at the date

(a) In general. In computing days of presence in the United States, an alien is considered to be present if the individual is physically present in the United States at any time during the day (see §301.7701(b)-1(c)(2)(i)). However, for purposes of section 7701(b) and the regulations under that section, the following

United States. The residency starting date for an alien who meets the lawful permanent resident test (green card test), described in paragraph (b)(1) of §301.7701(b)-1, is the first day during the calendar year in which the individual is physically present in the United States as a lawful permanent resident. The residency starting date for an alien who satisfies both the substantial presence

liters). Director of the service center. A director of an internal revenue service center. Distilled spirits plant. An establishment qualified under part 19 of this chapter (excluding alcohol fuel plants) for producing, warehousing, or processing of distilled spirits (including denatured spirits), or manufacturing of articles.

Prior Provisions A prior section 13107, Pub. L. 98–89, Aug. 26, 1983, 97 Stat. 596, established the National Recreational Boating Safety and Facilities

such injury or disease may be rebutted by clear and convincing evidence to the contrary. [26 FR 1580, Feb. 24, 1961, as amended at 28 FR 3088, Mar. 29, 1963; 39 FR 34530, Sept. 26, 1974]

Miliary tuberculosis. Service connection for miliary tuberculosis involving the lungs is to be determined in the same manner as for other active pulmonary tuberculosis. [26 FR 1591, Feb. 24, 1961, as amended at 27 FR 6387, July 6, 1962; 31 FR 4681, Mar. 19, 1966; 39 FR 34532, Sept. 26, 1974; 43 FR 45347, Oct. 2, 1978; 54 FR 34981, Aug. 23, 1989]

proceeds of the financial assistance are to be used. Prior Provisions A prior section 3217, Pub. L. 89–136, title VII, §707, Aug. 26, 1965, 79 Stat. 573; Pub. L. 94–273, §26, Apr. 21, 1976, 90 Stat. 380, required annual report to

59604, Nov. 3, 1999; 65 FR 21128, Apr. 20, 2000; 67 FR 8465, Feb. 25, 2002; 69 FR 2295, Jan. 15, 2004; 69 FR 52418, Aug. 26, 2004; 70 FR 33325, June 7, 2005; 75 FR 4252, Jan. 26, 2010]

§760.906. Adjustments will be applied in accordance with paragraphs (d) and (e) of this section. (b) The 2005-2007 LIP national payment rate for eligible livestock owners is based on 26 percent of the average fair market value of the livestock. (c) The 2005-2007 LIP national payment rate for eligible livestock contract growers is based on 26 percent of the average income loss

(2) [Reserved] (c) The Board may assign such other administrative powers and duties to the Administrative Committee as it shall determine, and the Administrative Committee shall act on behalf of and in the name of the Board in all administrative matters. [37 FR 17379, Aug. 26, 1972, as amended by Amdt. 6, 42 FR 55879, Oct. 20, 1977; 44 FR 25621, May 2, 1979; 50 FR 25199, June 18, 1985; 56 FR

by constituted authorities empowered to issue such obligations are the obligations of such a unit. However, section 103(a)(1) and this section do not apply to industrial development bonds except as otherwise provided in section 103(c). See section 103(c) and §§1.103-7 through 1.103-12 for the rules concerning interest paid on industrial development bonds. See section 103(d) for rules concerning

Section 105(b) provides an exclusion from gross income with respect to the amounts referred to in section 105(a) (see §1.105-1) which are paid, directly or indirectly, to the taxpayer to reimburse him for expenses incurred for the medical care (as defined in section 213(e)) of the taxpayer, his spouse, and his dependents (as defined in section 152). However, the exclusion does not apply to

, however, section 105(d) and §1.105-4. However, for purposes of section 105(c), it is immaterial whether an amount is paid in a lump sum or in installments. Section 105(c) does not apply to amounts which are treated as workmen's compensation under paragraph (b) of §1.104-1, or to amounts paid by reason of the death of the employee (see section 101).

distributed, in the hands of the beneficiary is determined by the rules set forth in section 662(b) and the regulations thereunder. See paragraphs (h)(1)(ii) and (j)(1)(ii) of §1.668(b)-2. (b) The total of the amounts treated under section 666 as having been distributed by the trust on the last day of a preceding taxable year of the trust are included as prescribed in

(a) Whenever it appears that the basis of property in the hands of the taxpayer is a substituted basis, as defined in section 1016(b), the adjustments indicated in §§1.1016-1 to 1.1016-6, inclusive, shall be made after first making in respect of such substituted basis proper adjustments of a similar nature in respect of the period during which the property was held by

Example: A, a single individual, computes a net operating loss of $15,000 for 1980 in accordance with the rules of §1.172-3, relating to net operating loss in case of a taxpayer other than a corporation. Included within A's computation of this net operating loss is a deduction arising under section

, make assessment and collection of such deficiency from such former subsidiary in an amount not exceeding the portion of such deficiency which the Commissioner may determine to be allocable to it. If the Commissioner makes assessment and collection of any part of a deficiency from such former subsidiary, then for purposes of any credit or refund of the amount collected from such former subsidiary the agency of the common parent under the provisions of