24344(c) is the foreign investment interest offset, which disallows
part of the overall interest deduction that is related to the water's-edge dividends not included in the measure of tax under Sec.
an S corporation's deductions for expenses of providing corporate aircraft for personal use by shareholders or employees, where these expenses exceed the value of flights included in these individuals' incomes under the methodology prescribed by Regs.
IRC section 56(b)(1)(A)(ii) disallows
the deduction for any "taxes described in" section 164(a).
If Congress enacted the proposal to disallow
deductions for the cost of compensatory damages under certain environmental laws, it would create an artificial distinction in the tax law for certain types of costs associated with the manufacture and distribution of products.
1502-20 in effect disallows
stock basis deemed to reflect built-in gain and duplicated loss, there is an incentive to shift stock basis to debt basis in certain situations.
According to a representative from the state Budget Director's Office, HB 272 was also intended to disallow
intercompany intangible expenses; technical corrections will be sought in 2006 to correct this error for tax years beginning after 2004.
In the final minute of the second period, with the Kings leading 2-1, video-goal judge Malcolm Ashford - invoking powers granted those officials this season - called down to Walkom to disallow
an apparent goal by Philippe Boucher because Moger was in the crease.
In notice 2001-17 (2001-1 CB 730) the IRS announced it would disallow
losses claimed from contingent liability transactions.
274(e)(2) and (9) specifically disallow
expenses related to entertainment facilities to the extent "specified individuals" do not recognize the related income.
At no time did Sewell disallow
anyone, black, white, Hispanic, Asian or female, from applying for the training program.
The IRS proposed to disallow
the losses in full for both tax years because the trustee, Fortson, failed to meet the IRC's material participation requirements.