For deductions in respect of a decedent, see section 691. Editorial Notes Amendments

person's agent, nominee, or other person acting under the direction or control of a notified person for purposes of 26 U.S.C. 7609(e) if the person with respect to whose liability the summons is issued has the ability in fact or at law to cause the agent, etc., to take the actions permitted under 26 U.S.C. 7609(b

(a) Purpose and scope. This section provides a temporary regulation that if and when adopted as a final regulation, will be added to paragraph (b) of §1.897-3. Paragraph (b) of this section would then appear as paragraph (b)(4) of

(a) In generalThe component members of a controlled group of corporations on a December 31 shall, for their taxable years which include such December 31, be limited for purposes of this subtitle to one $250,000 ($150,000 if any component member is a corporation described in section 535(c)(2)(B)) amount for purposes of computing the

(a) Controlled group of corporationsFor purposes of this subpart, all employees of all corporations which are members of the same controlled group of corporations shall be treated as employed by a single employer. In any such case, the credit (if any) determined under section 51(a) with respect to each such member shall be its

bond (as defined in paragraph (b)(2) of §1.1232-3). (2) In the case of a bond issued by a corporation after December 31, 1954, as part of an investment unit consisting of an obligation and an option, the issue price of the bond is determined by allocating the amount received for the investment unit to the individual elements of the unit in the manner set forth in

section 11 or 801, as the case may be, for the year of the loss and elects to have the provisions of this section apply with respect to such loss. (2) Time, manner, and scopeAn election under paragraph (1) shall be made at such time and in such manner as the Secretary may prescribe by regulations. An election made with respect to any foreign expropriation loss shall apply

disseminators of “news”), electronic outlets for print newspapers, magazines, and television and radio stations, and web-only outlets or other alternative media as methods of news delivery evolve. For “freelance” journalists to be regarded as working for a news organization, they must demonstrate a solid basis for expecting publication through that organization, whether print or electronic. A publication contract would be the clearest proof, but OSC may also look to the past publication record of a

(a) Reduction in certain preference items, etc.For purposes of this subtitle, in the case of a corporation— (1) Section 1250 capital gain treatmentIn the case of section 1250 property

(c) Fee categories. There are four categories of FOIA requesters for fee purposes: “commercial use requesters,” “representatives of the news media,” “educational and non-commercial scientific institution requesters,” and “all other requesters.” The categories are defined in the following paragraphs (c)(1) through (5), and applicable fees, which are the same for two of the categories, will be assessed as specified in paragraph (d) of this section.

Any person succeeding to and carrying on a business for which the special tax imposed by section 4411 has been paid, and any taxpayer changing his residence address or his place of business, without registering such change as provided in §§44.4905-1 and 44.4905-2 shall be liable to an additional tax, and to the penalty prescribed in section 6651 for failure to make a return. (For regulations

Any individual who— (A) is required to furnish information under section 408(o)(4) as to the amount of designated nondeductible contributions made for any taxable year, and (B) overstates the amount of such contributions made for such taxable year, shall pay a penalty of $100 for each

section 736(a), to a retiring partner or successor in interest of a deceased partner. (3) Substantial appreciationFor purposes of paragraph (1)— (A) In generalInventory items of the partnership shall be considered to have appreciated substantially in value if their fair market value exceeds 120 percent of the adjusted

(1) For limitations on credits and refunds, see subchapter B of chapter 66. (2) For overpayment in case of adjustments to accrued foreign taxes, see section 905(c). (3) For credit or refund in case of deficiency dividends paid by a personal holding company, see

§ 552.33 Media. The Warden shall assign staff to handle all news releases and news media inquiries in accordance with the rule on Contact with News Media (see 28 CFR 540.65).

(a) General rule. Organizations described in section 170(b)(1)(A) (other than in clauses (vii) and (viii)) are excluded from the definition of private foundation by section 509(a)(1). For the requirements to be met by organizations described in section 170(b)(1)(A) (i) through (vi), see §1.170A

(a) General ruleThere shall be allowed as a credit against the tax imposed by this subtitle for the taxable year an amount equal to the sum of the amounts payable to the taxpayer— (1) under section 6420 (determined without regard to

previously made. (3) The computation by the Secretary, pursuant to section 6014, of the tax imposed by chapter 1 shall be considered as having been made by the taxpayer and the tax so computed considered as shown by the taxpayer upon his return. (4) For purposes of subsection (a)— (A) any excess of the

(1) For provisions relating to registration in connection with firearms, see sections 5802, 5841, and 5861. (2) For special rules with respect to registration by persons engaged in receiving wagers, see section 4412.

certificates for use in connection with a particular development, which requires the developer to furnish to the issuing authority and the homebuyer a certificate that the price for the residence is no higher than it would be without the use of a mortgage credit certificate. Under regulations, rules similar to the rules of subparagraphs (B) and (C) of section 143(a)(2)

from which such dividends were paid for the affected year or years. (4) Foreign taxes deemed paid under section 960. In the case of foreign taxes paid under section 960 (or under section 902 in the case of an amount treated as a dividend under section 1248), the rate of exchange determined under §1.964-1 for translating accrued

request for a waiver must be made in accordance with applicable published guidance, publications, forms, instructions, or other guidance on the IRS.gov Internet Web site. See §601.601(d)(2)(ii)(b) of this chapter. The waiver will specify the type of filing (that is, a registration statement or notification under section 6057) and the period to which it applies. In

§301.6692-1(c) and rules similar to the rules in §301.6724-1(c)(3)(ii) (regarding undue economic hardship related to filing information returns on magnetic media) will apply. (d) Meaning of terms. The following definitions apply for purposes of this

(a) Any real estate investment trust whether or not such trust meets the requirements of section 857(a) and paragraph (a) of §1.857-1 for any taxable year beginning after December 31, 1960 shall apply paragraph (b) of this section in computing its earnings and profits for such taxable year. (b) In the determination of the earnings and

§1.1312-5, §1.1312-6, and §1.1312-7, the maintenance of an inconsistent position is a condition necessary for adjustment. The requirement in such circumstances is that a position maintained with respect to the taxable year of

§ 2530.204-3 Alternative computation methods for benefit accrual. (a) General. Under section 204(b)(3)(A) of the Act and section 411(b)(3)(A) of the Code, a defined benefit pension plan may determine an employee's service for purposes of benefit accrual on the basis of accrual

(a) Exempted foreign-related items. (1) Returns of information are not required for payments that a payor can, prior to payment, reliably associate with documentation upon which it may rely to treat as made to a foreign beneficial owner in accordance with §1.1441-1(e)(1)(ii) or as made to a

(a) Scope. This section explains the meaning to be given certain terms and items in section 907(c) (1), (2), and (4). See also §§1.907(a)-0(b) and 1.907(c)-2 for further definitions. (b) FOGEI—(1) General rule.

For limitations in case of— (1) Deficiency dividends of a personal holding company, see section 547. (2) Tentative carry-back adjustments, see section 6411. (3) Service in a