Background on Regulations Under Sections 482, 483, and 2032A of the Internal Revenue Code: Scheduled for a Hearing Before the Subcommittee on Oversight of the Internal Revenue Service of the Committee on Finance on April 27, 1981U.S. Government Printing Office, 1981 - 19 lappuses |
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amount application of section apply arbitrarily shift buyer cash lease closely-held business comparable land Cong contract controlled corporate bonds crop share rentals current use valuation decedent decedent's death deductions deferred sales price determining eligible for current estate purchase money estate tax fair market value Farm Credit Administration farm or closely-held farm real estate Federal land banks formula method gift tax gross estate imputed under section interest income interest payments interest rate imputed Internal Revenue Service issue legislative history loans material participation test multiple factor method ordinary income organizations present interest present law present value prime rate proposed regulations purposes of section qualified heir qualified real property qualify for current rate of interest rates charged rates under sections related businesses requirement sale or exchange sales price payment seller sponsored by Senator tion trade or business Treas Treasury Implementation Treasury regulations provide treated as interest uncontrolled taxpayer unstated interest valuation method