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References in periodicals archive ?
other reasonable methods must allocate costs to specific inventory items.
A donor cannot allocate GST exemption to an inter vivos transfer (a transfer the donor makes during his lifetime) if the property would be included in his or her spouse's gross estate (other than under IRC section 2035) if the donor died immediately after the transfer.
The example concludes that since the president's travel is engaged in for lobbying and non-lobbying purposes, the taxpayer must reasonably allocate the travel expense between the two purposes.
Although a trustee who allocates capital gain to trust income with a power to adjust must do so "reasonably and impartially," the regulations neither define nor illustrate this concept.
The principal reason costs may be higher is because the expense amount a company records for new shares will be based on the fair market value of the shares the plan allocates to participant accounts--measured at the time of allocation--rather than on the amount of the cash contribution the company makes to the ESOP to repay the loan.
In another questionable stance, the IRS held in Letter Ruling 200144003 that a distributor of certain component products used in the manufacture of vehicles had to allocate storage and handling costs to merchandise in transit, but not yet received.
The entity should allocate other costs not identifiable with a particular component of the activity between fundraising and the appropriate program or management and general function.
Except as provided in paragraph (e)(12)(vi) (6), the taxpayer shall allocate a deduction for a charitable contribution solely to foreign source gross income if the taxpayer, at the time of the contribution, knows or has reason to know that --
However, Congress realized that tax advisers were often failing to properly allocate the GST exemption to trusts ultimately intended to benefit skip persons.
corporations apportion and allocate interest expense on the basis of assets taking into account all assets of the U.
A corporate general partner or any limited partner cannot allocate its share of partnership interest expenses between foreign- and U.
Schiff added, "With numerous commodity trading advisors (CTAs) participating in our managed foreign exchange program, clients of PFG can allocate to any one of them at the click of a button.