U.S. Tax Reporter: Income

U.S. Tax Reporter: Income is designed for tax professionals who prefer doing their federal income tax research using a code-based product. It provides a comprehensive, up-to-date source of federal income tax law via the Internal Revenue Code, regulations, committee reports, cases, rulings, explanations, and annotations of cases and rulings.

Organized by Code section and document type, U.S. Tax Reporter: Income simplifies your research, saving time and providing instant access to the information you need. It's conveniently updated in place so there's no need to track down recent developments. With this Guide you'll get the benefit of:

• A highly experienced, full-time staff of experts to ensure you have consistent, high quality analysis and comprehensive coverage of federal income tax law, including citations to authorities
• Annotations that are organized by both Code section and legal issue, and cite to the American Federal Tax Reports, other case reporters and rulings
• Smart paragraphing that tells you at a glance if the paragraph deals with the code section at hand; the researcher can even tell the Code section from the paragraph number located in the topic index
• Editor's commentary in the form of Observations, Tax Tips, Recommendations, Cautions and Examples that provide professional insights above and beyond the explanation of the law
• Federal Taxes Weekly Alert Newsletter on Checkpoint provides commentary and reports on all significant federal tax developments
• The RIA Federal Tax Handbook that provides quick on point answers to your day-to-day tax questions

In short, U.S. Tax Reporter: Income is the premier code-based income tax research tool for tax professionals.

List of Content (Click any title to expand the list)
Code Arranged Explanations

• Income
  • Determination of Tax Liability (¶14 -- ¶59B8.4)
    • Tax Rates (¶14 -- ¶154)
      • ¶14 Overview—taxing the income of individuals and trusts and estates.
      • ¶24 Married individuals and surviving spouse filing joint returns; heads of household.
      • ¶34 Tax Tables for individuals.
      • ¶114 Tax on corporations.
      • ¶154 Change of rate during the year.
    • Tax Credits (¶214 -- ¶528.4)
      • ¶214 Credit for child and dependent care expenses.
      • ¶224 Credit for the elderly and the disabled.
      • ¶244 Child tax credit for qualifying children under age 17.
      • ¶254 Credit for interest on certain home mortgages—mortgage credit certificates (MCCs).
      • ¶25A4 Credit for higher education expenses—combined “Hope Scholarship credit/American Opportunity tax credit (AOTC)” and “Lifetime Learning credit.”
      • ¶264 Limits on nonrefundable personal tax credits.
      • ¶274 Credit for foreign and U.S. possession taxes.
      • ¶304 Credit for qualified plug-in electric vehicles (QPEVs) acquired before Jan. 1, 2012.
      • ¶30B4 Alternative motor vehicle credit for fuel cell, hybrid, lean-burn technology, alternative fuel, and converted plug-in vehicles.
      • ¶30C4 Credit for qualified alternative fuel vehicle (QAFV) refueling property.
      • ¶30D4 Credit for new qualified plug-in electric drive motor vehicles.
      • ¶314 Tax withheld on wages.
      • ¶324 Earned income credit.
      • ¶364 First-time homebuyer credit for purchases after April 8, 2008 and before Oct. 1, 2010.
      • ¶36A4 Making work pay credit for 2009 and 2010.
      • ¶36B4 Premium tax credit and cost-sharing reductions—after 2013.
      • ¶384 General business credit.
      • ¶394 Carryback and carryforward of unused credits.
      • ¶404 Alcohol fuels credit.
      • ¶40A4 Biodiesel fuels credit.
      • ¶414 Research credit for amounts paid or incurred before Jan. 1, 2014.
      • ¶418.4 Pre-'87 employee stock ownership credit.
      • ¶424 Low-income housing credit—general rules.
      • ¶434 Enhanced Oil Recovery (EOR) Credit.
      • ¶454 Credit for electricity produced from certain renewable resources, production of refined coal and production of Indian coal.
      • ¶45C4 Credit for clinical testing for drugs (orphan drug credit) to treat rare conditions.
      • ¶45D4 New markets tax credit (NMTC) through calendar year 2013 (and carryover of unallocated credits through calendar year 2018) for investment in qualified community development entities (CDEs).
      • ¶45F4 Employer-provided child care credit.
      • ¶45K4 Credit for producing fuel from nonconventional sources.
      • ¶45Q4 Credit for qualified carbon dioxide sequestration.
      • ¶45R4 Small employer health insurance credit.
      • ¶464 Investment credit.
      • ¶474 Rehabilitation credit for property placed in service after '90; investment credit recapture rules for property placed in service before '91.
      • ¶484 Energy credit for property placed in service after '90; definitions and special rules for the investment credit for property placed in service before '91.
      • ¶48D4 Qualifying therapeutic discovery project (QTDP) credit or grant for 2009 and 2010.
      • ¶504 Special investment credit rules.
      • ¶514 Work opportunity tax credit (WOTC).
    • Alternative Minimum Tax (¶534 -- ¶584)
      • ¶534 Credit for prior-year minimum tax liability—the minimum tax credit.
      • ¶544 Nonrefundable tax credit allowed to holders of clean renewable energy bonds
      • ¶54A4 Nonrefundable tax credit allowed to holders of qualified tax credit bonds.
      • ¶54B4 Qualified forestry conservation bonds.
      • ¶54C4 New clean renewable energy bonds (new CREBs).
      • ¶54D4 Qualified Energy Conservation Bonds.
      • ¶54E4 Qualified Zone Academy Bonds (QZABs).
      • ¶554 Alternative minimum tax (AMT).
      • ¶564 How the AMT is computed for certain corporations with qualified timber gain.
      • ¶574 Items of tax preference.
    • Environmental Tax (¶594 -- ¶59B8.4)
  • Gross Income -- Taxable Income (¶614 -- ¶684)
    • ¶614 Gross income defined.
    • ¶624 Adjusted gross income.
  • Alimony Annuities (¶714 -- ¶904)
    • ¶714 Alimony.
    • ¶724 Annuities in general.
    • ¶734 Services of child.
    • ¶744 Prizes and awards.
    • ¶774 Election to include in income proceeds of commodity credit loans.
    • ¶784 Certain foreign taxes as dividends.
    • ¶794 Group-term life insurance.
    • ¶804 Restoration of value of securities after expropriation loss.
    • ¶824 Reimbursement of pre-1994 moving expenses.
    • ¶834 Restricted property.
    • ¶854 Unemployment compensation.
    • ¶864 Social security and railroad retirement benefits.
  • Exclusions (¶1014 -- ¶139D4)
    • Life Insurance Proceeds, Gifts & Inheritances (¶1014 -- ¶1024)
      • ¶1014 Life insurance proceeds and employee death benefits.
      • ¶1024 Gifts and bequests in general.
    • Interest on State & Local Bonds (¶1034 -- ¶103A8.4)
      • ¶1034 Interest on state and local bonds.
    • Disability Benefits (¶1044 -- ¶1064)
      • ¶1044 Compensation for injuries or sickness.
      • ¶1054 Employee accident and health plans.
      • ¶1064 Employer's contributions to accident and health plans.
    • Other Exclusions (¶1074 -- ¶139D4)
      • ¶1074 Rental value of parsonage.
      • ¶1084 Income from discharge of a debt.
      • ¶1094 Exclusion from gross income of lessee's improvements to lessor's property.
      • ¶1114 Tax benefit rule.
      • ¶1124 Combat zone compensation exclusion.
      • ¶1138.4 Prior law—mustering-out pay for Armed Forces.
      • ¶1154 Income of states and municipalities.
      • ¶1168.4 Pre-'87 dividends received deduction.
      • ¶1174 Scholarships.
      • ¶1184 Contributions to corporation capital.
      • ¶1194 Meals and lodging furnished for employer convenience. Basic rules.
      • ¶1204 Qualified group legal services plans.
      • ¶1214 Exclusion of gain from the sale or exchange of a principal residence.
      • ¶1218.40 One-time exclusion for gain on sale of residence—sales and exchanges before May 7, '97.
      • ¶1224 Servicemen's retirement pay.
      • ¶1234 Amounts received under insurance contracts for certain living expenses.
      • ¶1254 Cafeteria plans.
      • ¶1264 Certain cost-sharing conservation payments.
      • ¶1274 Educational assistance programs.
      • ¶1288.4 Prior law—interest on “all-savers” certificates.
      • ¶1294 Dependent care assistance programs.
      • ¶1304 Exclusion for payments received for accepting assignment of personal injury liability under structured settlement arrangements.
      • ¶1314 Exclusion of qualified foster care payments received.
      • ¶1324 Certain fringe benefits.
      • ¶1338.40 [Prior Law] Pre-August 21, 1996 interest exclusion for loans to acquire employer securities.
      • ¶1354 U.S. savings bond interest used for higher education.
      • ¶1384 Medicare Advantage medical savings accounts (Medicare Advantage MSAs).
  • Tax-Exempt Bonds Personal Exemptions (¶1414 -- ¶1538.4)
    • ¶1414 Private activity bonds.
    • ¶1424 Exempt facility private activity bonds.
    • ¶1434 Types of mortgage revenue bonds.
    • ¶1444 Qualified small issue, redevelopment, and student loan bonds.
    • ¶1454 Qualified 501(c)(3) bonds.
    • ¶1464 Volume cap.
    • ¶1474 Other requirements for private activity bonds.
    • ¶1484 Arbitrage.
    • ¶1494 Technical requirements for tax-exempt bonds.
    • ¶1504 Definitions and special rules.
    • ¶1514 Personal and dependency exemptions—in general.
    • ¶1524 Exemptions for dependents.
  • Business Expenses (¶1614 -- ¶1624)
    • ¶1614 Allowance of deductions.
    • ¶1624 Trade or business expenses.
  • Interest Deductions Taxes (¶1634 -- ¶1644)
    • ¶1634 Deduction for interest—overview.
    • ¶1644 Deductible taxes.
  • Losses Bad Debts (¶1654 -- ¶1664)
    • ¶1654 Losses.
    • ¶1664 Bad Debts.
  • Depreciation (¶1674 -- ¶1694)
    • ¶1674 Depreciation
    • ¶1684 Modified accelerated cost recovery system (MACRS) depreciation.
    • ¶1688.400 Accelerated cost recovery system (ACRS) for property placed in service in '81 through '86
  • Charitable Contributions (¶1704 -- ¶1714)
    • ¶1704 Charitable contributions.
    • ¶1714 Amortizable bond premium.
  • Net Operating Losses Other Business Expenses (¶1724 -- ¶1994)
    • ¶1724 Overview of the net operating loss (NOL) deduction.
    • ¶1734 Circulation expenditures.
    • ¶1744 Research and experimental expenditures.
    • ¶1754 Farmers' election to deduct soil or water conservation, erosion prevention and endangered species recovery expenditures.
    • ¶1764 Social security taxes as to employees of foreign subsidiaries.
    • ¶1778.4 Pre-'87 trademark and trade name expenditures.
    • ¶1794 Election to expense certain depreciable business assets in lieu of depreciation.
    • ¶179B4 Small business refiners' expensing of certain Environmental Protection Agency (EPA) compliance costs.
    • ¶1814 Election to expense certain costs of qualified film and television productions commencing after Oct. 22, 2004 and before Jan. 1, 2014.
    • ¶1828.40 Pre '86 farmers' land clearing expenditures.
    • ¶1834 Deductions attributable to activities not engaged in for profit.
    • ¶1858.40 Pre-'87 amortization of railroad grading and tunnel bores.
    • ¶1864 Recoveries of damage for antitrust violations etc.
    • ¶1918.40 Amortization of pre-'82 rehabilitation expenditures for certified historic structures.
    • ¶1924 Contributions to black lung benefit trusts.
    • ¶1934 Deduction for tertiary injectant expenses.
    • ¶1944 Expensing and amortization of reforestation expenditures.
    • ¶194A4 Contributions to employer withdrawal liability payment trusts.
    • ¶1954 Deduction of business start-up costs.
    • ¶1964 Deduction for certain unused business credits.
    • ¶1974 15-year amortization of certain intangibles.
    • ¶1984 Election to expense qualified environmental remediation expenses.
    • ¶1994 Domestic production activities deduction.
  • Additional Individual Deductions (¶2114 -- ¶2234)
    • Nonbusiness Expenses (¶2114 -- ¶2124)
      • ¶2124 Expenses for production of income.
    • Medical (¶2134 -- ¶2134)
      • ¶2134 Medical expenses.
    • Other Deductions (¶2154 -- ¶2234)
      • ¶2154 Alimony and related payments.
      • ¶2164 Cooperative-housing—stockholder's taxes, interest and business depreciation.
      • ¶2174 Moving expenses.
      • ¶2194 Deductions for contributions to individual retirement plans (IRAs).
      • ¶2204 Archer medical savings account (Archer MSA) defined.
      • ¶2214 Deduction for interest on qualified education loans (student loan interest deduction).
      • ¶2218.40 Pre-'87 two-earner married couples.
      • ¶2224 Higher Education Expense Deduction Before 2014.
      • ¶2228.40 Pre-'87 adoption expenses.
      • ¶2234 Health savings accounts (HSAs).
  • Special Corporate Deductions (¶2414 -- ¶2914)
    • Special Corporate Deductions (¶2414 -- ¶2624)
      • ¶2434 Dividends received deductions.
    • Capital Expenditures (¶2634 -- ¶2734)
      • ¶2634 Capital expenditures.
      • ¶263A4 Uniform capitalization rules—Introduction.
      • ¶2644 Life, health, and accident insurance.
      • ¶2674 Related parties—disallowance of losses or accrued expenses and interest.
      • ¶2694 Acquisitions made to evade or avoid tax.
    • Travel, Entertainment & Gift Expenses (¶2744 -- ¶2914)
      • ¶2744 Disallowance of certain entertainment, gift, and travel expenses.
      • ¶280A4 Overview.
      • ¶280C4 Certain expenses for which credits are allowable.
      • ¶280F4 Limits on depreciation write-offs for passenger automobiles and listed property.
      • ¶280G4 “Golden parachute” payments.
  • Corporate Distributions & Liquidations (¶3014 -- ¶3464)
    • Distributions (¶3014 -- ¶3184)
      • ¶3014 Corporate distributions to shareholders.
      • ¶3024 Redemptions in general.
      • ¶3034 Redemptions to pay death taxes and funeral and administration expenses.
      • ¶3044 Redemption through related corporations.
      • ¶3054 Stock dividends and rights.
      • ¶3064 Preferred stock bail-outs.
      • ¶3074 Stock dividends and rights—Basis.
      • ¶3114 Gain or loss to distributing corporations on nonliquidating distributions.
      • ¶3124 Earnings and profits.
      • ¶3164 Dividend defined.
      • ¶3174 Definitions of property and redemption under the corporate distribution rules.
      • ¶3184 Constructive ownership of stock.
    • Liquidations (¶3314 -- ¶3464)
      • ¶3314 Liquidations under IRC §331.
      • ¶3324 Complete liquidation of a subsidiary.
      • ¶3344 Basis of property received in liquidation.
      • ¶3364 Gain or loss of liquidating corporation.
      • ¶3374 Nonrecognition to liquidating corporation on distributions in complete liquidation of subsidiaries.
      • ¶3378.40 Prior law: 12-month liquidations.
      • ¶3384 Election to treat stock purchase as asset acquisition.
      • ¶3464 Redemptions as complete or partial liquidations.
  • Corporate Organizations & Reorganizations (¶3514 -- ¶3868.40)
    • Corporate Organizations & Reorganizations (¶3514 -- ¶3748.40)
      • ¶3514 Transfer to controlled corporation.
      • ¶3544 Exchanges of stock and securities in certain reorganizations.
      • ¶3554 Divisive reorganizations and distributions.
      • ¶3564 Receipt of boot in reorganizations and divisions.
      • ¶3574 Assumption of liability in organizations and reorganizations.
      • ¶3584 Basis to distributees in organizations and reorganizations.
      • ¶3614 Nonrecognition of gain or loss to corporations in reorganization.
      • ¶3624 Basis to corporations on organization and reorganization.
      • ¶3674 Exchanges involving foreign corporations.
      • ¶3684 Reorganization definitions.
      • ¶3708.4 Prior law—insolvency proceedings started before October 1, 1979.
    • Carryovers (¶3814 -- ¶3868.40)
      • ¶3814 Carryovers in certain corporate acquisitions.
      • ¶3824 Limitation on net operating loss carryforwards and certain built-in losses following ownership change.
      • ¶3828.40 Special limitations on carryovers for pre-'87 changes.
      • ¶3834 Special limitation on certain excess credits.
      • ¶3844 Limit on use of preacquisition losses to shelter built-in gains.
      • ¶3854 Interest in corporation as stock or debt.
      • ¶3868.40 Prior law—transfers of partnership and trust interests by corporations.
  • Employee Benefit Plans, Self-employed Benefit Plans, Employee Stock Options (¶4014 -- ¶4364)
    • Employee Benefit Plans, Self-employed Benefit Plans, Employee Stock Options (¶4014 -- ¶409A4)
      • ¶4014 Basic rules for qualified retirement plans.
      • ¶4024 Basic rules for taxing beneficiaries on distributions from and contributions to retirement plans.
      • ¶4034 Employee annuities.
      • ¶4044 Employer deduction for contributions to qualified plan and other deferred compensation plans.
      • ¶404A4 Deduction rules applicable to foreign deferred compensation plans.
      • ¶4064 Covering employees of foreign affiliates under an American employer's qualified plan.
      • ¶4074 Qualified plan coverage of U.S. citizens of certain U.S. subsidiaries in business abroad.
      • ¶4084 IRAs and Simplified Employee Pensions.
      • ¶4094 Employee stock ownership plans.
      • ¶409A4 Inclusion in gross income of deferred compensation under nonqualified deferred compensation plans.
    • Participation, Vesting, Funding (¶4104 -- ¶4204)
      • ¶4104 Minimum participation standards and minimum coverage requirements.
      • ¶4114 Minimum standards for vesting and accrual of benefits; restrictions on forfeiture, reduction, and mandatory distribution of accrued benefits.
      • ¶4124 Minimum Funding Standards.
      • ¶4134 Multiemployer plans and union plans.
      • ¶4144 Definitions and special rules.
      • ¶4154 Limits on benefits and contributions.
      • ¶4164 Top-heavy plans.
      • ¶4174 Survivor annuities and related rules.
      • ¶4184 Financially troubled multiemployer plans in reorganization.
      • ¶418A4 Notice of multiemployer plan reorganizations.
      • ¶418B4 Funding requirements for multiemployer plans in reorganization.
      • ¶418C4 Overburden credit for multiemployer plans in reorganization.
      • ¶418D4 Adjusting benefits of multiemployer plans in reorganization.
      • ¶418E4 Benefit payments under insolvent multiemployer plans.
      • ¶4194 Deducting contributions made to funded welfare benefit plans.
      • ¶419A4 “Qualified asset account” of a welfare benefit plan.
      • ¶4204 Qualified transfers of excess pension assets to fund retiree health and life insurance benefits.
    • Employee Stock Options (¶4214 -- ¶4364)
      • ¶4214 Compensatory options to buy stock or other property.
      • ¶4224 Incentive stock options (ISOs).
      • ¶4234 Employee stock purchase plans (ESPPs).
      • ¶4244 Definitions and special rules for statutory stock options.
      • ¶4304 Contributions for defined benefit plans (other than multiemployer plans).
      • ¶4314 Minimum funding standards—after 2007.
      • ¶4324 Additional Funding Rules for Multiemployer Plans in Endangered or Critical Status
      • ¶4364 Funding-based limits imposed on benefits and benefit accruals under single-employer defined benefit plans.
  • Tax Accounting (¶4414 -- ¶4604)
    • Accounting Periods (¶4414 -- ¶4444)
      • ¶4424 Change of accounting period.
    • Accounting Methods (¶4464 -- ¶4514)
      • ¶4464 Methods of accounting.
      • ¶4474 Accounting for corporations engaged in farming.
      • ¶4484 Limits on use of cash method of accounting.
      • ¶4514 Taxable year of inclusion in gross income of income items (time that income must be reported)—in general.
    • Time for Reporting Income (¶4534 -- ¶4534)
      • ¶4534 Installment and deferred payment sales.
    • Installment Sales (¶453A4 -- ¶453C8.400)
      • ¶453A8.40 Pre-'88 dispositions—dealers in personal property.
      • ¶453B4 Disposition of installment obligations.
    • Other Reporting Rules (¶4544 -- ¶4604)
      • ¶4544 Obligations issued at a discount.
      • ¶4554 Election by accrual-method taxpayers to defer income from prepaid subscriptions.
      • ¶4604 Accounting for long-term contracts.
  • Accounting Rules -- Deductions (¶4614 -- ¶4834)
    • Accounting Rules -- Deductions (¶4614 -- ¶468B4)
      • ¶4614 General rules for timing of deductions.
      • ¶4674 Deferred, prepaid, increasing and decreasing payments for use of property or for services.
      • ¶468A4 Nuclear power plant decommissioning costs.
      • ¶468B4 Designated settlement funds and qualified settlement funds (QSFs).
    • Passive Activities Limits (¶4694 -- ¶4704)
      • ¶4694 Passive activity loss limitations.
      • ¶4704 Limit on tax-exempt use losses.
    • Inventories (¶4714 -- ¶4754)
      • ¶4714 General rules for inventories.
      • ¶4724 LIFO inventories.
      • ¶4754 Mark-to-market rules for securities dealers.
    • Adjustments (¶4814 -- ¶4834)
      • ¶4824 Allocation of income and deductions.
      • ¶4834 Imputing interest on certain deferred payments.
  • Exempt Organizations (¶5014 -- ¶5054)
    • ¶5014 Tax-exempt organizations.
    • ¶5024 Feeder organizations.
    • ¶5034 Prohibited transactions between exempt organizations and closely-related persons.
    • ¶5044 Organization's status after loss of tax exemption due to excessive lobbying.
    • ¶5054 Additional qualification requirements for certain tax-exempt organizations.
  • Private Foundations, Unrelated Business Income (¶5074 -- ¶5304)
    • ¶5074 Private Foundations.
    • ¶5124 Unrelated business taxable income.
    • ¶5134 “Unrelated trade or business” defined for purposes of UBTI.
    • ¶5144 Unrelated debt-financed income.
    • ¶5214 Exemption of farmers' cooperatives.
    • ¶5274 Taxation of political organizations.
    • ¶5294 Qualified tuition programs.
    • ¶5304 Coverdell education savings accounts (Coverdell ESAs) defined.
  • Accumulated Earnings Tax (¶5314 -- ¶5374)
    • ¶5324 Corporations subject to the Accumulated Earnings Tax.
    • ¶5354 Accumulated taxable income subject to the accumulated earnings tax.
  • Personal Holding Companies, Banks (¶5414 -- ¶5974)
    • ¶5424 Personal holding company defined.
    • ¶5434 Personal holding company income.
    • ¶5444 Constructive stock ownership for personal holding company tax purposes.
    • ¶5454 Personal holding company tax computation.
    • ¶5474 Deficiency dividends.
    • ¶5614 Deduction for dividends paid defined.
    • ¶5624 Dividends defined.
    • ¶5814 Banks in general.
    • ¶5934 Reserve for bad debts—years beginning before January 1, 1996.
    • ¶5944 Alternative tax.
  • Natural Resources (¶6114 -- ¶6384)
    • Depletion (¶6114 -- ¶6158.40)
      • ¶6114 Depletion deduction—in general.
      • ¶6124 Basis for cost depletion.
      • ¶6134 Computation of percentage depletion.
      • ¶613A4 Limitations on percentage depletion of oil and gas wells.
      • ¶6144 Definition of property for depletion purposes.
    • Development & Exploration Expenditures (¶6164 -- ¶6174)
      • ¶6164 Development expenditures—minerals other than oil and gas.
      • ¶6174 General rules. Exploration expenditures—unlimited deduction.
    • Specially Treated Payments & Transfers (¶6218.40 -- ¶6384)
      • ¶6218.40 Prior law—payments to encourage defense mining.
      • ¶6314 Coal, domestic iron ore and timber transactions.
      • ¶6364 Mineral production payments.
      • ¶6384 Continental shelf areas.
  • Estates & Trusts (¶6414 -- ¶6924)
    • ¶6414 Imposition of income tax on estates and trusts.
    • ¶6424 Deductions and credits of estates and trusts.
    • ¶6434 Definitions and Special Rules.
    • ¶6454 Election to treat qualified revocable trust as part of estate for income tax purposes.
    • ¶6514 Simple trust.
    • ¶6524 Simple trust—taxation of beneficiary.
    • ¶6614 Estate or complex trust—deduction for distributions.
    • ¶6624 Estate or complex trust—taxation of beneficiary.
    • ¶6634 Estates or complex trust—special rules.
    • ¶6644 Charitable remainder trusts (CRTs).
    • ¶6654 Definitions and Scope.
    • ¶6714 Income and deductions of a grantor or other person treated as the owner of any portion of a trust.
    • ¶6724 Definitions and Rules.
    • ¶6734 Reversionary Interests and Short-Term Trusts.
    • ¶6764 Power to revoke.
    • ¶6774 Trusts created with income for benefit of grantor.
    • ¶6914 Income in Respect of Decedents.
    • ¶6924 Abatement of Tax for Members of Armed Forces.
  • Partnerships (¶7014 -- ¶7774)
    • ¶7024 Income and credits of partner.
    • ¶7034 Partnership's computations.
    • ¶7044 Partner's distributive share.
    • ¶7054 Adjusted basis of partner's interest.
    • ¶7064 Tax years of partners and partnerships.
    • ¶7074 Transactions between partner and partnership.
    • ¶7084 Partnership terminations, combinations or split-ups.
    • ¶7094 Organization and syndication fees.
    • ¶7214 Contributions to partnership.
    • ¶7224 Basis of contributing partner's interest.
    • ¶7234 Basic rule for contributions of property.
    • ¶7244 Retention of character of contributed partnership property.
    • ¶7314 Recognition of gain or loss on distributions.
    • ¶7324 Basis of distributed property.
    • ¶7334 Adjustment of partner's basis to reflect distributions.
    • ¶7344 Special adjustments to basis of undistributed partnership property.
    • ¶7354 Character of gain or loss on disposition of property distributed from a partnership.
    • ¶7364 Payments to a retiring partner or a deceased partner's successor in interest.
    • ¶7374 Recognition of precontribution gain on partnership distributions to the contributing partner.
    • ¶7414 Gain or loss on transfer of interest in a partnership.
    • ¶7424 Basis of transferee partner's interest.
    • ¶7434 Special adjustment to basis of partnership property.
    • ¶7514 Partnership unrealized receivables and substantially appreciated inventory.
    • ¶7524 Treatment of liabilities assumed by partner or partnership.
    • ¶7534 Income Received in Respect of Deceased Partner.
    • ¶7544 Manner of Electing Optional Adjustment to Basis of Partnership Property.
    • ¶7614 Definitions and election of nonapplication of rules.
    • ¶7714 Simplified flow-through rules for electing large partnerships.
  • Insurance Companies (¶8014 -- ¶8484)
    • ¶8324 Nonlife company income subject to tax.
  • RICS, REITS, REMICS (¶8514 -- ¶860L4)
    • ¶8514 Requirements for being taxed as a regulated investment company.
    • ¶8524 Taxation of regulated investment companies and shareholders.
    • ¶8554 Dividends paid after close of taxable year.
    • ¶8564 Real Estate Investment Trusts.
    • ¶8574 Taxation of real estate investment trusts and their shareholders.
    • ¶8604 Deduction for deficiency dividends.
    • ¶860A4 Real estate mortgage investment conduits.
    • ¶860H4 Financial Asset Securitization Investment Trusts (FASITs)—pre-Jan. 1, 2005 rules.
  • General Rules For Foreign Income (¶8614 -- ¶9434)
    • Determination of Source of Income (¶8614 -- ¶8614)
      • ¶8614 U.S. source income.
    • Nonresident Aliens & Foreign Corporations (¶8624 -- ¶8654)
      • ¶8634 Allocation of other income & deduction items.
      • ¶8644 Definitions and special rules.
      • ¶8654 Source rules for personal property.
    • Foreign Tax Credit (¶8714 -- ¶8984)
      • ¶8714 Who is a nonresident alien.
      • ¶8724 Gross income.
      • ¶8774 Expatriation to avoid tax after June 3, 2004 and before June 17, 2008.
      • ¶8814 Income of foreign corporations.
      • ¶8824 Income “effectively connected” with U.S. business and how it is taxed.
      • ¶8944 Income affected by treaty.
      • ¶8974 Disposition of investments in U.S. real property
    • Other Benefits (¶9014 -- ¶9434)
      • ¶9014 Foreign tax credit—general rules.
      • ¶9024 Domestic corporation's “deemed paid credit” for taxes paid by foreign affiliates.
      • ¶9034 Credit for taxes “in lieu” of income taxes.
      • ¶9044 Limitation on Credit.
      • ¶9054 Procedural rules.
      • ¶9064 Nonresident aliens and foreign corporations.
      • ¶9074 Foreign oil and gas income.
      • ¶9084 Reduction of credit for boycott participation.
      • ¶9114 Foreign earned income exclusion.
      • ¶9124 Allowances for U.S. employees abroad.
      • ¶9314 Income from U.S. possessions.
      • ¶9374 Residence and source rules relating to possessions.
  • Controlled Foreign Corporations (¶9514 -- ¶9824)
    • ¶9514 Includible amounts.
    • ¶9524 Definition of Subpart F income.
    • ¶9534 Insurance income.
    • ¶9544 Foreign base company income.
    • ¶9554 Previously excluded Subpart F income from qualified investment.
    • ¶9564 Investment of earnings in U.S. property.
    • ¶9574 Controlled foreign corporation defined.
    • ¶9584 Attribution rules.
    • ¶9594 Effect of distributions.
    • ¶9604 Special rules for foreign tax credit.
    • ¶9614 Basis of stock.
    • ¶9624 Relief provisions.
    • ¶9644 Miscellaneous provisions.
    • ¶9704 Export trade corporations.
    • ¶9824 Admissibility of foreign documents.
  • Foreign Currency Rules (¶9854 -- ¶9994)
    • ¶9854 Functional currency.
    • ¶9864 Foreign taxes and earnings and profits.
    • ¶9874 Translation of branch income.
    • ¶9884 Foreign currency gains and losses.
    • ¶9894 Other rules.
    • ¶9914 Domestic International Sales Corporation (DISC)—DISC exemption.
    • ¶9924 Qualification requirements.
    • ¶9934 Definitions.
    • ¶9944 Inter-company pricing rules.
    • ¶9954 Tax on small interest charge DISC's stockholders.
    • ¶9964 Actual distributions to stockholders.
    • ¶9974 Special Subchapter C rules.
    • ¶9994 International boycott determinations.
  • Gain or Loss -- Basis (¶10,014 -- ¶10,238.4)
    • ¶10,014 Gain or loss determination.
    • ¶10,114 Basis.
    • ¶10,124 Cost as the basis of property.
    • ¶10,144 Basis of property acquired from or passing from a decedent.
    • ¶10,154 Gifts and transfers in trust.
    • ¶10,164 Adjustments to basis.
    • ¶10,174 Discharge of indebtedness.
    • ¶10,224 Elective modified carryover basis system for property acquired from decedents dying in 2010.
  • Nontaxable Exchanges Special Situations (¶10,314 -- ¶11,118.40)
    • ¶10,314 Tax-free exchanges of like-kind property held for productive use or investment.
    • ¶10,334 Nonrecognition of gain from involuntary conversions.
    • ¶10,344 Rollover of gain on the sale or exchange of residence—sales and exchanges before May 7, '97.
    • ¶10,454 Elective rollover of gain from qualified small business stock (QSB stock) to other QSB stock.
  • Capital Gains & Losses (¶12,014 -- ¶12,984)
    • Computations (¶12,014 -- ¶12,124)
      • ¶12,024 Temporary alternative tax of 15% on capital gains for corporations with qualified timber gains.
      • ¶12,124 Carryover and carryback of capital losses.
    • Definitions (¶12,214 -- ¶12,314)
      • ¶12,214 Capital assets defined.
      • ¶12,224 Other terms relating to capital gains and losses defined.
      • ¶12,234 Holding period for capital assets.
      • ¶12,314 IRC §1231 gains and losses.
    • Gains & Losses (¶12,328.4 -- ¶12,328.4)
      • ¶12,328.4 Bonds and other evidences of indebtedness—pre-'84 TRA rules.
    • Bonds & Other Debt Instruments, Pre '84 TRA (¶12,32A8.4 -- ¶12,32B8.4)
    • Recapture & Other Special Rules (¶12,334 -- ¶12,604)
      • ¶12,334 Recapture and other special rules—short sales.
      • ¶12,344 Options—gain or loss on sale or exchange.
      • ¶12,354 Patents—transfers of all substantial rights treated as capital gain or loss transactions.
      • ¶12,364 Securities dealers—identification of investment securities.
      • ¶12,374 Certain subdivided real property treated as not held for sale.
      • ¶12,388.4 Prior law—amortization in excess of depreciation.
      • ¶12,444 Small business corporation (Section 1244) stock.
      • ¶12,454 Depreciation recapture for personal property and certain real property.
      • ¶12,464 Foreign investment company stock—pre-2005 tax years.
      • ¶12,484 Gain on disposition of stock in certain foreign corporations.
      • ¶12,494 Gain on certain transfers to controlled foreign corporations.
      • ¶12,504 Recapture of depreciation on certain real property.
      • ¶12,518.4 Prior law—recapture of farm losses on disposition of farm property.
      • ¶12,524 Recapture on disposition of farm land.
      • ¶12,534 Transfers of franchises, trademarks, and trade names.
      • ¶12,544 Recapture on disposition of certain interests in mines, wells and other natural deposits.
      • ¶12,554 Recapture on premature disposition of cost-sharing conservation payments.
      • ¶12,564 Gain and loss timing and character rules for section 1256 contracts and certain other property.
      • ¶12,574 Disposition of converted wetlands or highly erodible croplands.
    • Bonds & Other Debt Instruments, Post '84 TRA (¶12,714 -- ¶12,984)
      • ¶12,714 Original issue discount (OID) rules.
      • ¶12,764 Disposition of market discount bonds.
      • ¶12,814 Acquisition discount on certain short-term obligations.
      • ¶12,864 Tax treatment of stripped bonds.
      • ¶12,874 Registration of bonds.
      • ¶12,884 Original issue discount on tax-exempt obligations.
      • ¶12,914 Passive foreign investment companies.
      • ¶12,954 Qualified electing fund.
  • Tax Readjustments, S Corporations, Cooperatives (¶13,014 -- ¶14,00U-34)
    • ¶13,014 Income averaging for farmers and fishermen.
    • ¶13,414 Repayment of income reported under claim of right rule.
    • ¶13,514 Foreign expropriation loss recoveries.
    • ¶13,614 What corporations can elect Subchapter S treatment.
    • ¶13,624 Election.
    • ¶13,634 Impact of election on corporation.
    • ¶13,664 Pass-through of items to S corporation shareholders.
    • ¶13,674 Shareholder's basis in S corporation stock or debt
    • ¶13,684 Distributions by S corporations.
    • ¶13,714 Coordination of S corporation rules with C corporation rules.
    • ¶13,744 Tax imposed on built-in gains.
    • ¶13,754 S corporation income from passive sources.
    • ¶13,794 Effective date of S corporation rules.
    • ¶13,799.09 Pre-1983 subchapter S rules for small business corporations
    • ¶13,814 Cooperatives
    • ¶13,97E4 Credit to holders of qualified zone academy bonds (QZABs) issued before Oct. 4, 2008.
    • ¶13,984 Individual debtor's bankruptcy estate treated as a separate taxable entity.
    • ¶14,004 Designation of District of Columbia Enterprise Zone as an Empowerment Zone.
    • ¶14,00B4 Zero-percent capital gains rate applies to certain sales of DC Zone assets.
    • ¶14,00E4 Tax-favored renewal communities.
    • ¶14,00F4 Income exclusion for “qualified capital gain” from the sale or exchange of certain renewal community assets acquired after 2001.
    • ¶14,00L4 Tax benefits for the New York Liberty Zone.
    • ¶14,00N4 Tax benefits for areas affected by Hurricanes Katrina, Rita or Wilma.
    • ¶14,00P4 Monthly $600 exclusion for up to six months for lodging furnished in-kind to employees—as Hurricane Katrina relief (until July 1, 2006), or 2008 Midwestern disaster relief (until May 1, 2009).
    • ¶14,00R4 Employee retention credit for employers in the Gulf Opportunity Zone (GO Zone), Rita GO Zone, Wilma GO Zone, Hurricanes Katrina, Rita, and Wilma, and the Kansas Disaster Area
    • ¶14,00S4 Charitable contribution limitations were suspended for certain qualified contributions.
    • ¶14,00U-14 $10 billion in recovery zone economic development bonds and $15 billion in recovery zone facility bonds are authorized for issuance in 2009 and 2010.
  • Self-Employment Income Withholding on Nonresident Aliens & Foreign Corps. (¶14,014 -- ¶14,944)
    • ¶14,014 Tax on self-employment income—imposition of tax.
    • ¶14,024 Self-Employment Income.
    • ¶14,114 Overview of net investment income tax.
    • ¶14,414 Withholding on nonresident aliens, foreign corporations, and foreign partnerships in general.
    • ¶14,454 Withholding on Dispositions of Real Property by Foreign Persons.
    • ¶14,614 Reporting of amounts subject to withholding and tax withheld and adjustments of tax withheld.
    • ¶14,714 Taxes to enforce reporting on U.S. owned foreign accounts—foreign financial institutions (FFIs).
    • ¶14,724 Taxes to enforce reporting on U.S. owned foreign accounts—nonfinancial foreign entities.
    • ¶14,744 Special rules for FATCA withholding.
  • Consolidated Returns (¶15,014 -- ¶33,014)
    • ¶15,024 Consolidated returns.
    • ¶15,514 Disallowance of benefits of graduated corporate rates and accumulated earnings credit.
  • Withholding, Employment Taxes (¶34,014 -- ¶35,104)
    • ¶34,014 Scope of wage withholding in general.
    • ¶34,024 Computation of wage and fringe benefit withholding.
    • ¶34,034 Employer's liability for tax.
    • ¶34,064 Backup withholding.
    • ¶35,014 Collection and payment of taxes.
  • Penalty Excise Taxes (¶47,014 -- ¶58,914)
    • ¶49,114 Public charity optional lobbying rules.
    • ¶49,414 Excise taxes on self-dealing.
    • ¶49,424 Undistributed income.
    • ¶49,454 Taxes on taxable expenditures.
    • ¶49,664 Excise taxes on taxable distributions from donor advised funds.
    • ¶49,674 Excise tax on prohibited benefits from a donor advised fund.
    • ¶49,714 Excise tax on underfunded employee retirement plans.
    • ¶49,754 Prohibited transactions with retirement plans, Archer medical savings accounts (Archer MSAs), health savings accounts (HSAs), and Coverdell education savings accounts (Coverdell ESAs).
    • ¶49,80B4 Excise tax on failure to satisfy group health plan continuation coverage (COBRA) requirements.
    • ¶49,80F4 Notice requirements for significant reductions in the rate of future benefit accruals—“section 204(h) notice.”
    • ¶49,80G4 Failure of employer to make comparable health savings account (HSA) contributions.
    • ¶49,80I4 Excise tax on high-cost employer-sponsored health coverage—after 2017.
    • ¶49,854 Overview of tax on stock compensation of expatriated corporation insiders.
  • Returns (¶60,014 -- ¶61,164)
    • Income Tax Returns (¶60,014 -- ¶60,214)
      • ¶60,114 Requirement to make an income tax return or information statement.
      • ¶60,124 Who must file an income tax return.
      • ¶60,134 Joint returns.
      • ¶60,154 Relief from joint and several liability on joint returns—innocent spouse and separate liability elections and equitable relief.
      • ¶60,158.15 Prior Law—declaration of individual estimated tax.
    • Information Returns (¶60,314 -- ¶60,604)
      • ¶60,314 Partnership returns.
      • ¶60,414 Information reporting at the source.
      • ¶60,434 Information returns reporting corporate liquidations or liquidating distributions, and acquisitions of control or changes in capital structure.
      • ¶60,454 Returns by brokers and barter exchanges.
      • ¶60,474 Information reporting for retirement plans.
      • ¶60,494 Returns and statements for interest and original issue discount (OID).
      • ¶60,50I4 Reporting cash received.
      • ¶60,50M4 Reporting by federal agencies concerning contracts.
      • ¶60,50S4 Reporting requirements for qualified tuition and related expenses and interest on qualified higher education loans.
      • ¶60,554 Post-2013 health insurance coverage provider's information reporting and statement requirements.
      • ¶60,564 Post-2013 “applicable large employer's” health insurance coverage information reporting and statement requirements.
    • Signing and Filing (¶60,614 -- ¶60,654)
    • Filing (¶60,714 -- ¶60,914)
      • ¶60,814 Extension of time for filing returns.
    • Other Rules (¶60,964 -- ¶61,164)
      • ¶61,034 Confidentiality of return information.
      • ¶61,094 Taxpayer identifying numbers.
      • ¶61,104 Public inspection of written determinations.
      • ¶61,114 Disclosure and list maintenance for tax shelter reportable transactions.
  • Payment of Tax (¶61,514 -- ¶66,314)
    • Time & Place for Payment (¶61,514 -- ¶61,674)
    • Assessment & Deficiency Procedures (¶62,014 -- ¶62,554)
      • ¶62,014 Assessments.
      • ¶62,114 Definition of a deficiency.
      • ¶62,124 Notice of deficiency.
      • ¶62,134 Restrictions on deficiencies; Petition to tax court.
      • ¶62,144 Determinations by Tax Court.
      • ¶62,214 Tax treatment of partnership items.
    • Collection (¶63,014 -- ¶63,654)
      • ¶63,014 General collection provisions.
      • ¶63,044 IRS Fair Tax Collection Practices.
      • ¶63,214 General tax lien rules.
      • ¶63,234 Priority of federal tax liens and certain competing claims.
      • ¶63,254 Administrative remedies for release or discharge of lien.
      • ¶63,264 Administrative appeal of liens.
      • ¶63,314 Levy and seizure.
      • ¶63,354 Sale of seized property and administrative release from levy.
      • ¶63,404 Records of sales of seized property.
    • Refunds & Credits (¶64,014 -- ¶64,324)
      • ¶64,014 Amounts treated as overpayments.
      • ¶64,024 Authority and procedure for credits and refunds.
      • ¶64,114 Tentative Carryback and Refund Adjustments.
      • ¶64,284 2008 recovery rebate credit.
      • ¶64,294 Advance payment of increased 2003 child tax credit
      • ¶64,314 Issuer's election of refundable tax credit for “qualified” bonds.
    • Limitations Period (¶65,014 -- ¶65,324)
      • ¶65,014 Assessment or collection without assessment.
      • ¶65,024 Period for collection after assessment.
      • ¶65,034 Suspension of limitation period.
      • ¶65,114 Time for filing claim—amount refundable.
      • ¶65,124 Overpayments found by Tax Court.
      • ¶65,214 Mitigation—Related taxes under different chapters.
      • ¶65,314 Time limitations for criminal prosecutions of tax law violations.
      • ¶65,324 Refund suits and recovery of refunds; third party suits.
    • Interest on Underpayments & Overpayments (¶66,014 -- ¶66,314)
      • ¶66,014 Interest on underpayments, nonpayments and extensions.
      • ¶66,034 Taxpayer's cash deposits to pay taxes
  • Penalties, Jeopardy Assessments Bankruptcy (¶66,514 -- ¶68,736)
    • ¶66,514 Additions for failure to file return or pay tax.
    • ¶66,524 Failure to file certain information returns, registration statements, etc.
    • ¶66,534 Returns due before '90—additions for negligence and fraud.
    • ¶66,544 Failure to pay individual estimated tax.
    • ¶66,554 Addition to tax for failure to pay corporate estimated tax.
    • ¶66,564 Failure to deposit taxes.
    • ¶66,624 Overview of the accuracy-related penalty
    • ¶66,634 Civil fraud penalty.
    • ¶66,644 Definitions and special rules for accuracy-related penalties and fraud penalty.
    • ¶66,824 Penalty for providing false information with respect to withholding or backup withholding.
    • ¶66,844 100% penalty for willful and flagrant or repeated violations involving excise taxes on private foundations and other exempt organizations.
    • ¶66,924 Penalty for failure to file actuarial report by defined benefit plan.
    • ¶66,954 Other assessable penalties relating to tax return preparers.
    • ¶67,044 Penalty for failure to keep records for reporting on deferred compensation plans and annuities subject to withholding.
    • ¶67,074 Failure by material advisor to report reportable transactions (including listed transactions).
    • ¶67,084 Failures to keep lists of advisees with respect to reportable transactions.
    • ¶67,124 Penalty for failure to disclose treaty-based return position.
    • ¶67,244 Waiver, definitions and special rules.
    • ¶67,514 Procedural requirements for penalty assessments.
    • ¶68,514 Termination assessments of income tax.
    • ¶68,614 Jeopardy assessments of income, estate, gift, and certain excise taxes.
    • ¶68,634 Stay of collection of termination or jeopardy assessment.
    • ¶68,726 Tax claims and tax determinations in bankruptcy.
    • ¶68,727 Priority of tax claims in insolvency and fiduciary's liability—overview.
    • ¶68,734 Survival of tax liability after bankruptcy or receivership.
  • Transferees, Closing Agreements, Crimes (¶69,014 -- ¶73,447)
    • ¶69,014 Transferred Assets.
    • ¶69,024 Proof of transferee liability.
    • ¶71,214 Closing agreements.
    • ¶71,224 Offers in compromise.
    • ¶71,234 Appeals dispute resolution procedures—early referral, mediation and arbitration.
    • ¶72,014 Penalty for willful evasion of tax.
    • ¶73,014 Forfeiture of taxable property.
    • ¶73,024 Possession of property used in violation of tax laws.
    • ¶73,254 Seized personal property worth $100,000 or less.
    • ¶73,446 Trial and Appeal Procedure in Criminal Tax Cases.
    • ¶73,447 Evidence in general.
  • Court Proceedings (¶74,014 -- ¶74,914)
    • Court Proceedings (¶74,014 -- ¶74,094)
      • ¶74,034 Suits for collection and enforcement of lien.
    • Proceedings by Taxpayers & Third Parties (¶74,214 -- ¶74,364)
      • ¶74,214 Prohibition on suits to restrain assessment or collection.
      • ¶74,217 Mandamus and declaratory judgments in tax cases.
      • ¶74,224 Refund suits.
      • ¶74,304 Recovery of costs and fees by prevailing taxpayers in administrative and court proceedings.
      • ¶74,336 Jurisdiction of courts and related matters —Overview.
      • ¶74,337 Res judicata and collateral estoppel— Overview.
      • ¶74,338.400 Estoppel—Overview.
    • Tax Court (¶74,414 -- ¶74,914)
      • ¶74,536 Introduction to Tax Court Rules.
      • ¶74,536.0254 Time computations and extensions.
      • ¶74,824 Review of Tax Court decisions.
      • ¶74,914 Burden of proof and burden of production.
  • Misc. Provisions, IRS Procedures (¶75,014 -- ¶75,284)
    • ¶75,024 Timely mailing as timely filing and paying.
    • ¶75,08A4 Extension of deadlines for disaster victims for filing certain returns, paying certain taxes, and for performing other required acts.
  • Discovery of Liability & Enforcement Procedures (¶76,014 -- ¶76,559.7658)
    • Discovery of Liability & Enforcement Procedures (¶76,014 -- ¶76,556)
      • ¶76,024 Authority of IRS to examine books and records.
      • ¶76,234 Rewards to informers (whistleblowers) who report tax law violations to the IRS.
    • Statement of Procedural Rules (¶76,557.401 -- ¶76,557.401)
    • Practice Before the IRS (¶76,559.7658 -- ¶76,559.7658)
      • ¶76,559.7658 TREASURY DEPARTMENT CIRCULAR NO. 230.
  • Taxpayers Classified, Definitions, General Principles (¶77,014 -- ¶98,334)
    • ¶77,014 Definitions.
    • ¶77,024 Life insurance contracts defined for tax purposes.
    • ¶77,02A4 Taxation of modified endowment contracts.
    • ¶77,02B4 Taxation of long-term care insurance.
    • ¶77,034 Determination of marital status.
    • ¶77,044 Publicly traded partnerships treated as corporations.
    • ¶78,014 Authority of Treasury Department.
    • ¶78,024 Organization plans and related material.
    • ¶78,054 Rules and regulations.
    • ¶78,114 Taxpayer Assistance Orders (TAOs).
    • ¶78,514 Effective date and related provisions.
    • ¶78,714 Limited status as state for Indian tribal governments.
    • ¶78,724 Overview of below-market loans.
    • ¶78,734 Indian fishing rights.
    • ¶78,744 Corporate inversion transactions.
    • ¶79,006 Substance v. form.
    • ¶98,124 Mental health and substance use disorder benefits under group health plans—parity with medical benefits.
    • ¶98,154 Treatment of PHSA group health plan and health insurance issuer provisions as if included in Code.
• Estate & Gift
  • Estate Tax (¶20,014 -- ¶22,108.4)
    • Rates & Credits (¶20,014 -- ¶20,164)
      • ¶20,014 Imposition and rate of estate tax.
      • ¶20,104 Unified credit against estate tax.
    • Gross Estate (¶20,314 -- ¶20,464)
      • ¶20,314 Definition of gross estate.
      • ¶20,315.32 Decedents dying and gifts made after 11-30-83 and before 5-1-89—Actuarial values II—Factors at 10% involving one and two lives —IRS Pub. 723E.
      • ¶20,334 Property owned at death.
      • ¶20,364 Transfers with retained life estate.
      • ¶20,374 Transfers taking effect at death.
      • ¶20,404 Joint interests.
      • ¶20,414 Powers of appointment.
      • ¶20,424 Proceeds of life insurance.
      • ¶20,434 Transfers for insufficient consideration.
    • Deductions (¶20,514 -- ¶20,584)
      • ¶20,534 Expenses, claims and indebtedness—deductibility for estate tax purposes.
      • ¶20,554 Charitable transfers.
      • ¶20,564 Marital deduction in general.
      • ¶20,56A4 Qualified domestic trusts (QDOTs).
      • ¶20,574 Pre-2004 deduction for qualified family-owned business interests (QFOBI).
    • Nonresident Aliens, Special Taxpayers (¶21,014 -- ¶22,108.4)
      • ¶21,014 Estate tax on nonresident aliens.
      • ¶21,044 Property within the United States defined for purposes of estate tax on nonresident aliens.
      • ¶21,054 Property outside the United States.
      • ¶21,064 Taxable estate of nonresident noncitizens.
      • ¶21,074 Expatriation to avoid estate tax—pre-June 17, 2008 expatriations.
      • ¶21,084 Burdensome foreign tax.
  • Gift Tax (¶25,014 -- ¶25,244)
    • ¶25,054 Unified credit against gift tax.
    • ¶25,114 Transfers in general.
    • ¶25,124 Valuation of gifts.
    • ¶25,134 Gifts by husband or wife to third party (gift splitting).
    • ¶25,184 Qualified disclaimers.
  • Generation-Skipping Transfer Tax (¶26,014 -- ¶26,644)
    • ¶26,014 Generation-skipping transfer (GST) tax imposed.
    • ¶26,124 Taxable terminations or distributions and direct skips.
    • ¶26,134 Non-skip persons.
    • ¶26,424 Inclusion ratio.
    • ¶26,634 Administration and return requirements.
  • Chapter 14 Rules (¶27,014 -- ¶49,80A4)
    • ¶27,044 Lapsing rights and restrictions.
  • Procedure & Forms: Returns -- Payments (¶60,014 -- ¶79,006)
    • Procedure & Forms: Returns -- Payments (¶60,014 -- ¶61,664)
      • ¶60,184 Estate tax return—U.S. citizen or resident.
      • ¶61,104 Public inspection of written determinations.
      • ¶61,664 Extensions for estates with closely held business interests.
    • Assessment & Collection (¶62,014 -- ¶65,314)
      • ¶62,114 Definition of a deficiency.
      • ¶62,124 Notice of deficiency.
      • ¶62,134 Restrictions on assessment and collection of deficiencies; petitions to Tax Court.
      • ¶62,144 Determinations by Tax Court.
      • ¶63,234 Priority of federal tax liens and certain competing claims.
      • ¶63,254 Administrative remedies for release or discharge of lien.
      • ¶63,264 Administrative appeal of liens.
      • ¶63,314 Levy and seizure.
      • ¶64,014 Amounts treated as overpayments.
      • ¶64,024 Authority and procedure for credits and refunds.
      • ¶65,014 Assessment or collection without assessment.
      • ¶65,024 Period for collection after assessment.
      • ¶65,034 Suspension of limitation period.
      • ¶65,114 Time for filing claim—amount refundable.
      • ¶65,124 Overpayments found by Tax Court.
      • ¶65,314 Time limitations for criminal prosecutions of tax law violations.
    • Interest -- Penalties Misc. Procedural Provisions (¶66,014 -- ¶79,006)
      • ¶66,014 Interest on underpayments, non-payments and extensions.
      • ¶66,514 Additions for failure to file return or pay tax.
      • ¶67,124 Penalty for failure to disclose treaty-based return position.
      • ¶67,514 Procedural requirements for penalty assessments.
      • ¶68,614 Jeopardy assessments.
      • ¶68,634 Stay of collection of termination or jeopardy assessment.
      • ¶71,224 Compromises.
      • ¶74,914 Burden of proof and burden of production.
      • ¶75,024 Timely mailing as timely filing and paying.
      • ¶75,08A4 Extension of deadlines for disaster victims.
      • ¶76,024 Authority of IRS to examine books and records.
      • ¶78,054 Rules and regulations.
      • ¶78,114 Taxpayer Assistance Orders (TAOs).
      • ¶78,514 Effective date and related provisions.
      • ¶78,524 Effective date and related provisions.
      • ¶78,714 Limited status as state for Indian tribal governments.
      • ¶78,724 Overview of below-market loans.
• Overviews - Excise
  • ¶40,009 Overview of Retail and Manufacturers Excise Taxes.
• Excise
  • Luxury & Other Retail Taxes Manufacturers Taxes (¶40,014 -- ¶42,256)
    • ¶40,414 Retail excise tax on diesel fuel, kerosene, alternative fuels.
    • ¶40,814 Removal-at-terminal excise tax on gasoline, diesel fuel and kerosene.
    • ¶41,014 Fuel tax registration and bond requirements; additional persons liable for tax where failure to pay is willful.
  • Facilities & Services, Communications Transportation by Air (¶42,514 -- ¶42,948.4)
    • ¶42,514 Excise tax on communications services.
    • ¶42,534 Exemptions from communications excise tax.
    • ¶42,614 Tax on transportation of persons by air.
    • ¶42,714 Tax on transportation of property by air.
    • ¶42,814 Special rules for applying aviation taxes.
  • Foreign Insurers -Wagering Highway Use Taxes Environmental Taxes (¶43,714 -- ¶47,014)
    • ¶43,714 Foreign insurers—wagering—highway use taxes—environmental taxes—miscellaneous taxes.
    • ¶44,114 Occupational tax on wagering.
    • ¶44,214 Miscellaneous wagering tax provisions.
    • ¶44,814 Excise tax on use of heavy highway vehicles.
    • ¶46,114 Environmental excise tax on Oil Spill Liability.
    • ¶46,814 Environmental excise tax on ozone-depleting chemicals (ODCs).
  • Occupational Taxes, Liquor Tobacco & Firearms Taxes (¶49,014 -- ¶51,814)
    • ¶49,014 General provisions relating to occupational taxes.
    • ¶50,009 Liquor Taxes.
  • Administrative Provisions (¶60,014 -- ¶95,119)
    • ¶63,214 General tax lien rules.
    • ¶63,234 Priority of federal tax liens and certain competing claims.
    • ¶63,254 Administrative remedies for release or discharge of lien.
    • ¶63,314 Levy and distraint—procedure and constitutionality.
    • ¶64,204 Refunds and credits for certain uses of gasoline.
    • ¶64,274 Refund of excise fuels tax for fuels not used for taxable purposes.
    • ¶75,024 Timely mailing as timely filing and paying.

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