...2) 695, 840. See S. Kept. 94-1236 (Conference Kept.), p. 432, 1976-3 CB (Vol. 3) 807, 836; General Explanation of the Tax Reform Act of 1976, prepared by the staff of the Joint Committee on Taxation, p. 125, 1976-3 CB (Vol. 2) 1, 137.) This provision was further revised by section...

...burden resulting from such special allocation. Ogden v. Commissioner, 84 TC at 884-885. The General Explanation of the Tax Reform Act of 1976 prepared by the Staff of the Joint Committee on Taxation explains the meaning of "substantial economic effect" as "whether the allocation...

...2) 695, 840. See S. Kept. 94-1236 (Conference Kept.), p. 432, 1976-3 CB (Vol. 3) 807, 836; General Explanation of the Tax Reform Act of 1976, prepared by the staff of the Joint Committee on Taxation, p. 125, 1976-3 CB (Vol. 2) 1, 137.) This provision was further revised by section...

...amounts actually placed at risk in an activity. To curb this abuse, Congress enacted section 465. General Explanation of the Tax Reform Act of 1976, prepared by the staff of the Joint Committee on Taxation, 1976-3 CB (Vol. 2) 47. Therefore, respondent may contest the amounts actually...

...income taxes should be eligible for capital gain treatment. E. Recapture Properties.— The general explanation of the Tax Reform Act of 1976 prepared by the Staff of the Joint Committee on Taxation makes the following statement : "It is also intended that where property passes...

...Cut Provisions, before the Senate Finance Committee, May 17, 1976 at page 89. See also the General Explanation of the Tax Reform Act of 1976 prepared by the Staff of the Joint Committee on Taxation, p. 239 (December 29, 1978). a Moreover, such recapture will occur even though...

...effective for transfers made after June 22, 1976. Commenting on the reasons for change, the General Explanation of the Tax Reform Act of 1976 prepared by the Staff of the Joint Committee on Taxation stated: "the Congress believed that the voting rights are so significant with...

...Cut Provisions, before the Senate Finance Committee, May 17, 1976 at pace K9. See also the General Explanation of the Tax Reform Act of 1976 prepared by the Staff of the Joint Committee on Taxation, p. 239 (December 29, 1976). ' Moreover, such recnntnre will occur even though...

...(emphasis added). Further, in the Description of HR 6715; Technical, Clerical and Conforming Amendments of the Tax Reform Act of 1976, prepared by the staff of the Joint Committee on Taxation (Part II B, par. 23, at p. 27), it is indicated that "the bill makes it clear...

...deficiency dividend procedure for real estate investment trusts ("REIT's"). As stated in the General Explanation of the Tax Reform Act of 1976, prepared by the staff of the Joint Committee on Taxation, dated December 29, 1976, in order to qualify as a REIT a trust must operate...