Thus, P recognizes no loss on the T stock sale and the loss disallowance
rule does not apply.
There has been no change in the company s position on the disallowance
of its foreign tax credits by the Internal Revenue Service (IRS).
The NAO report includes the depressing news that 'despite their efforts, Defra and the Rural Payments Agency believe that further increases in disallowance
are likely in the early years of the CAP 2015-2020'.
Chelameswar and Kurian Joseph that the government had approved the " new domestic natural gas policy" on October 18, 2014 while rais- RIL CMD Mukesh Ambani THE CASE SO FAR The SC posted the next hearing for March 20 during which it will examine the RIL's response to the CAG report that had sought disallowance
of about ` 2,179 crore expenditure that RIL incurred on drilling of wells and payments to contractors in KG- D6.
The notice asserts a liability for taxes, penalties and interest related to the disallowance
of foreign tax credits and other deductions claimed in connection with a financing transaction.
11) It is worth mentioning that the "link" requirement does not exist under the forward disallowance
rule of section 265(a).
The taxpayers petitioned the Tax Court for relief, arguing the disallowance
was not a change in accounting method and that the statute of limitation barred any assessment for amounts deducted from 1998-2002.
1502-20 was amended, and some of the technical provisions and examples relating to the stock basis effects of loss disallowance
But, from April, 2009, the Chancellor has swept that disallowance
away and replaced it with a restriction based on CO2 emissions.
In rendering the decision, the District Court drew a distinction between transfers that take the form of an assignment, which are subject to equitable subordination and disallowance
, and those that are regarded as sales, which the District Court said would not be unless the purchaser had notice of the inequitable conduct.
The IRS has rejected taxpayers' pleas, based on existing law, for primary purpose or incremental cost approaches in determining both the trigger for the entertainment deduction disallowance
of section 274(e)(2) and the amount of expenses that should be disallowed.
Increased value for loss carryovers, regardless of limits, because losses may decrease the amount of disallowance
in the mechanics of the basis disconformity method.
Following the effective date of the regulations, however, if P disposed of S for which a deemed dividend ofpre-1966 E&P was made, P's stock basis in S would be increased for purposes of the loss disallowance
rules (LDR) under Treas.
2001), excepts the type of deductions in this situation from disallowance
We do not have sufficient justification to recommend disallowance
of all or a portion of the valuation reimbursed to the developer,'' wrote J.