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In 2003 CRTC rejected a licence for a Catholic radio station in Toronto to serve the area's 1. 1, 1997 (years subsequent to the tax years at issue in Ceridian), the FTB had taken the position that as a result of Ceridian, CRTC [section]24410 was wholly inoperable, so that no DRD was permitted for dividends received from an insurance company; see Departmental Policy on Section 24410 Insurance Dividend Deductions, FTB Multistate Audit Program Mem. For the purpose of applying CRTC [section] 19778, relating to a higher interest rate for understatements of tax related to using a reportable transaction (which applies for taxable years beginning after December 31, 1998), the section applies for taxable years beginning after December 31, 1998. |
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