The Court said the clause demanded "a rule of substantial
equality of treatment for resident and nonresident taxpayers.
Examples of activities that did not create substantial
743 basis adjustment rules are mandatory (rather than being elective, as under prior law), when an interest in a partnership that has a substantial
BIL is transferred.
Companies may have a harder time avoiding the accuracy-related penalties for substantial
understatements of income tax that relate to relatively routine corporate tax planning initiatives -- tougher standards may apply to understatements attributed to "tax shelters.
The preamble states that the suggestion was not adopted because "a principal/primary purpose test does not avoid the necessity of determining the various purposes for engaging in an activity and weighing the relative importance of those purposes, and because it has a substantial
'cliff' effect that an allocation approach does not.
Before the AJCA, a 20% accuracy-related penalty applied to any substantial
Generally, married persons who file jointly are jointly and severally liable for the tax due, unless under the innocent spouse rule a spouse can show that (1) on the tax return there is a substantial
understatement of tax attributable to grossly erroneous items of the other spouse, (2) in signing the return, the spouse seeking relief had not known and had had no reason to know of such substantial
understatement and (3) taking into account all the acts and circumstances, it would be inequitable to hold the spouse liable for the deficiency.
On April 21, 1992, Tax Executives Institute submitted the following comments to the Internal Revenue Service on its proposed regulations under sections 6662(e) and 6662(h) of the Internal Revenue Code, relating to the imposition of the accuracy-related penalty for substantial
and gross valuation misstatements attributable to section 482 allocations.
KrisEnergy or the Company), an independent upstream oil and gas company, wishes to make a voluntary announcement regarding the divestment of holdings by a substantial
shareholder, KrisEnergy Holdings Ltd.
In May 2012, the IRS issued proposed regulations (REG-141075-09) to clarify specifically which conditions result in a substantial
risk of forfeiture under Sec.
What is "a substantial
risk of forfeiture" under IRC Section 83?
1 : large in amount <a substantial
The original statutory proposal, which was the subject of substantial
public comment, including those from TEI, was revised to require taxpayers to report a "compilation of state return data" to each state.