IRS Regulations Increasing Imputed Interest Rates and Interpreting Estate Tax Law Concerning Valuation of Family Farm and Other Business Properties: Hearing Before the Subcommittee on Oversight of the Internal Revenue Service of the Committee on Finance, United States Senate, Ninety-seventh Congress, First Session, April 27, 1981
United States. Congress. Senate. Committee on Finance. Subcommittee on Oversight of the Internal Revenue Service
U.S. Government Printing Office, 1981 - 256 lappuses
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acre administration agricultural allowed amount annual appear apply areas Bank basis believe benefits buyer capital cash rent Chairman charged Committee comparable concern Congress considered continue contract death decedent decedent's deduction deferred determine Durenberger effect election estate tax example fact fair family farm family members farmers Federal final Finance gain going hearing heir higher imputed interest rates included income increase inflation Internal Revenue Code Internal Revenue Service interpretation issue land lease least legislation loans lower material participation Minnesota operation payment percent period present problem proposed regulations purchase qualified question raised real estate real property reason regard rental result rule section 482 seller selling Senator GRASSLEY special use valuation statement Subcommittee taxpayers testimony Thank tion trade or business transactions transfer Treasury
15. lappuse - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.
138. lappuse - In any case of two or more organizations, trades, or businesses (whether or not Incorporated, whether or not organized In the United States, and whether or not affiliated) owned or controlled directly or Indirectly by the same Interests...
8. lappuse - Secretary or his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any such organizations, trades, or businesses.
243. lappuse - ... by the decedent or a member of the decedent's family and used for a qualified use, and (ii) there was material participation by the decedent or a member of the decedent's family in the operation of the farm or other business, and (D) such real property is designated in the agreement referred to in subsection (d) (2). (2) Qualified use. For purposes of this section, the term "qualified use...
6. lappuse - That in any case of two or more related trades or businesses (whether unincorporated or incorporated and whether organized in the United States or not) owned or controlled directly or indirectly by the same interests, the Commissioner may...
140. lappuse - Bureau was active in its support for estate tax relief in the Tax Reform Act of 1976 and the Revenue Act of 1978. The...
20. lappuse - In the case of livestock operations, the carrying capacity of the land; (7) Where the land is timbered, whether the timber is comparable to that on the subject property; (8) Whether the property as a whole is unified or whether it is segmented, and where segmented, the availability of the means necessary for movement among the different segments; (9) The number, types, and conditions of all buildings and other fixed improvements located on the properties and their location as it affects efficient...
17. lappuse - ... there must have been material participation in the operation of the farm or closely held business by the decedent or a member of his family in 5 years out of the 8 years immediately preceding the decedent's death (Code sees. 2034A (a) and (b)).
172. lappuse - ... average annual gross cash rental may be determined and that there is no comparable land from which the average net share rental may be determined, or (ii) where the executor elects to have the value of the farm for farming purposes determined under paragraph (8).