section 754 election
Income taxes: Partner's interest basis determination; special rules under section 705,
...In situations where a corporation acquires an interest in a partnership that holds stock in that corporation, a section 754 election is not in effect with respect to the partnership for the taxable year in which the corporation acquires the interest, and the partnership later sells ...
85 T.C. 1075 (1985), 2870-83, Atlantic Veneer Corp. v. C.I.R.
...Held, the required election was not made which would permit petitioner to have the benefit of the stments to basis pursuant to the provisions of sections 754 and 743, I.R.C. 1954 Code. . DENNIS I. MEYER, ...
554 F.2d 1140 (D.C. Cir. 1977), 75-1647, Joseph v. United States Civil Service Commission
... as or on behalf of an independent candidate in a partisan election 1 for local office in the District from the otherwise applicable ... regulation was exempt from the notice and comment provisions of section 4 of the Administrative Procedure Act, 5 U.S.C. § 553 (1970). 3 The ...
384 U.S. 73 (1966), 318, Burns v. Richardson
... as a basis, to be submitted to the court, for use in the 1966 election, (2) a constitutional amendment embodying pertinent provisions of the ...Such legislation may include legislative action under Article XV, Section 2, 4th paragraph, of the Constitution. Such legislation shall further ...
- 26 C.F.R. § 1.59A-7 - Application of base erosion and anti-abuse tax to partnerships
- 26 C.F.R. § 1.951A-3 - Qualified business asset investment
- 26 C.F.R. § 1.901(m)-4 - Determination of basis difference
128 T.C. 207 (T.C. 2007), 4204-06, Bakersfield Energy Partners, LP v. Commissioner of Internal Revenue
...Unless otherwise . . indicated, all section references are to the Internal Revenue Code in effect for the year in ...BEP made an election under section 754 to adjust the basis of the partnership assets (the ...
462 U.S. 725 (1983), 81-2057, Karcher v. Daggett
... 2 and an injunction against proceeding with the primary election for United States Representatives under the plan. A three-judge district ... that shall be "apportioned among the several States." 2 The section says nothing about the composition of congressional districts within a ...
851 F.2d 361 (9th Cir. 1988), 87-7422, Simons v. C.I.R.
...They claimed that the partnership filed an effective election, under 26 U.S.C. ("I.R.C.") § 754 (1987), in its amended return for 1978. ... Tax Court found taxpayers had failed to show that, even if a valid section 754 election had been made, it would have had any effect on their basis in ...
Disallowance of Partnership Loss Transfers, Mandatory Basis Adjustments, Basis Reduction in Stock of a Corporate Partner, Modification of Basis Allocation Rules for Substituted Basis Transactions, Miscellaneous Provisions; Correction
... (REG-144468-05) that is the subject of these corrections is under sections 704, 732, 734, 743, 755, and 1502 of the Internal Revenue Code. Need for ...)(3)(iii)(B)(1) should read ``Regardless of whether a section 754 election is in effect or a substantial built in loss exists with respect to the ...
567 U.S. 519 (2012), 11-393, National Federation of Independent Business v. Sebelius
... . . (b). Section 1396c gives the Secretary of Health and Human. Services the ... rights, such as the right to bear arms or vote in elections;. loss of employment opportunities; social stigma; and severe. ...
556 U.S. 247 (2009), 07-581, 14 Penn Plaza LLC v. Pyett
.... . refusing a stay of any action under section 3 of this title" or "denying a petition under section 4 of this title to ... a result, the lower courts erred in relying on the "doctrine of election of remedies" to bar the employee's Title VII claim. Id. , at 49,. 94 ...
416 U.S. 267 (1974), 72-1598, National Labor Relations Board v. Bell Aerospace Company
... On a petition by a labor union for a representation election, the National Labor Relations Board (NLRB) held that the buyers employed ... Section 7 of the Act, 29 U.S.C. § 157, provides that. [e]mployees shall have ...
Covered Asset Acquisitions
...section 901(m) of the Internal Revenue Code (Code) with respect to . transactions ...For these reasons, the comment is not adopted. 3. Foreign Basis Election. Basis difference with respect to an RFA is generally equal to the . ...
- 26 CFR 1.751-1 - Unrealized receivables and inventory items
Basis of partner's interest; determination; special rules,
... rules on determination of basis of a partner's interest under section 705. The final regulations are necessary to coordinate sections 705 and ... a partnership that holds stock in that corporation, a section 754 election is not in effect with respect to the partnership for the taxable year in ...
486 U.S. 750 (1988), 86-1042, City of Lakewood v. Plain Dealer Publ. Co.
... pressure to endorse the incumbent Mayor in an upcoming election, or to refrain. . from criticizing him, in order to receive a favorable ...Section 901.181, Codified Ordinances, City of Lakewood, provides:. The Mayor ...
- 26 CFR 1.168(k)-1 - Additional first year depreciation deduction
Income taxes: Basis of partner's interest; determination,
... rules on determination of basis of a partner's interest under section 705. The proposed regulations are necessary to coordinate sections 705 and ... a partnership that holds stock in that corporation, a section 754 election is not in effect with respect to the partnership for the taxable year in ...
76 T.C. 759 (1981), 11952-77, Hager v. C.I.R.
... 11. Election . Each of the Partners hereby elects, pursuant to Section 761(a) of the ...
377 U.S. 713 (1964), 508, Lucas v. Forty-Fourth General Assembly of Colorado
..., sued various officials having duties in connection with state elections challenging the apportionment of seats in both houses of the Colorado ...Section 63-1-2 of the Colorado Revised Statutes established certain population ...
Partnership Transactions Involving Equity Interests of a Partner
... the IRS published final and temporary regulations (TD 9722) under section 337(d) of the Internal Revenue Code (Code) in the Federal Register (80 FR ... applies regardless of whether the partnership has a Section 754 election in effect. The commenter suggested that the final regulations clarify how ...
398 F.3d 1 (1st Cir. 2004), 04-2610, Rossello-Gonzalez v. Calderon-Serra
.... The Puerto Rico Electoral Commission, a/k/a The Commonwealth Election Commission; Aurelio Gracia-Morales, individually and in his capacity as ... Plaintiffs' claims in the right to vote guaranteed in Article II, Section 2, of the Commonwealth Constitution. The complaint's subsequent references ...
- 26 CFR 1.1400l(b)-1 - Additional first year depreciation deduction for qualified New York Liberty Zone property