§1.953-5 which would, but for paragraph (a) of this section, be subject to the provisions of section 954, there shall be allowed, in determining the taxable income derived from the insurance of United States risks under §1.953-4, a deduction under section 809(a)(1) for the share of each and every item of investment yield

(a) In general. Requesting spouses may petition the Tax Court to review the denial of relief under §1.6015-1. (b) Time period for petitioning the Tax Court. Pursuant to section 6015(e), the requesting spouse may petition the Tax Court to review a denial of

1 of the next year. The first such report for calendar year 1987 activities must be submitted on or before July 1, 1988. [53 FR 4525, Feb. 16, 1988; 53 FR 12748, Apr. 18, 1988, as amended at 56 FR 29185, June 26, 1991; 64 FR 58751, Oct. 29, 1999; 72 FR 26553, May 10, 2007; 77 FR 23418, Apr. 19, 2012]

items required by paragraphs (e) and (f) of this section with respect to each reviewed year partner's share of partnership adjustments (as defined in §301.6241-1(a)(6)) associated with the imputed underpayment for which an election under §301.6226-1 is made. The statements furnished to the

for sale. Advance auction means an auction of advance allowances. Advance sale means a sale of advance allowances. Affected source means a source that includes one or more affected units. Affected States means

other qualified institutional buyers, that in the aggregate owns and invests on a discretionary basis at least $100 million in securities of issuers that are not affiliated with the entity: (A) Any insurance company as defined in section 2(a)(13) of the Act; Note: A purchase by an insurance company for one or more of its

of paragraphs (1), (2), (3), and (4) of section 4262(b), or (2) under regulations prescribed by the Secretary, transportation of property in the course of exportation (including shipment to a possession of the United States) by continuous movement, and in due course so exported. (c) Excess baggage of passengersFor

resale to persons authorized to purchase or receive specially denatured spirits in accordance with this part. The term does not include a person who only buys and sells specially denatured spirits which that person never physically receives or intends to receive. Denaturant. Any one of the materials authorized under part 21 of this chapter for addition to spirits in the production of denatured spirits.

payment of reportable death benefits subject to the reporting requirements of section 6050Y and §§1.6050Y-1 through 1.6050Y-4, §1.101-1(b) through (g) apply to reportable policy sales made after December 31, 2018, and to reportable death benefits paid after December 31, 2018. For any other purpose

§301.7430-2   Requirements and procedures for recovery of reasonable administrative costs. (a) Introduction. (b) Requirements for recovery. (1) Determination by the Internal Revenue Service. (i) Jurisdiction. (ii) Administrative proceeding. (iii) Administrative proceeding date. (iv) Reasonable administrative costs. (v) Prevailing

) 317-6934 (for general rules, including indirect ownership and look-through rules); concerning submissions and requests for a public hearing, Regina L. Johnson at (202) 317-6901 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Background I. In General This document contains proposed amendments to

document identifier or OMB control number. To be assured consideration, comments and recommendations must be submitted in any one of the following ways: 1. Electronically. You may send your comments electronically to http://www.regulations.gov. Follow the instructions for “Comment or Submission” or “More Search Options” to find the information collection document(s) that are accepting comments. 2

(c) Disclosure standard for other penalties is reasonable basis. The penalties for disregarding rules or regulations in section 6662(b)(1) and for a substantial understatement of income tax in section 6662(b)(2) may be avoided by adequate disclosure of a return position only if the position has at least a reasonable basis. See §1.6662-3(c) and

(c) The manufacturer of concentrate complies with all requirements for the protection of the revenue with respect to the production, removal, sale, transportation, and use of concentrate, and of the mash or juice from which it is produced, as may be prescribed by this part. (Sec. 201, Pub. L. 85-859, 72 Stat. 1392, as amended (26

) is permissible, but is limited to applications adopted by the International Maritime Organization (such as IMO SN.1/Circ.289) or those denoted in the International Association of Marine Aids to Navigation and Lighthouse Authorities' (IALA) ASM Collection for use in the United States or Canada, and to no more than one ASM per minute. Note to paragraph (d): The Coast Guard has developed the “U.S. AIS Encoding Guide

(a) Whenever the Secretary has fixed the free and restricted percentages for any fiscal period, as provided for in §929.52(a), each handler shall withhold from handling a portion of the cranberries acquired during such period. The withheld portion shall be equal to the restricted percentage multiplied by the volume of marketable cranberries acquired. Such withholding

(a) A majority of the Committee shall constitute a quorum. (b) The Committee shall, from among its members, select a chairman and such other officers and adopt such rules for the conduct of its business as it may deem advisable. (c) For any decision of the Committee to be valid, a concurring vote of at least five members is required, except as follows: (1) In matters

(a) No certificate holder may assign and no flightcrew member may accept assignment to any reserve or duty with the certificate holder during any required rest period. (b) Before beginning any reserve or flight duty period a flightcrew member must be given at least 30 consecutive hours free from all duty within the past 168 consecutive hour period. (c) If a flightcrew member operating in a new theater