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March 2002 Plain Language Regulations

Determination of Basis of Partner's Interest
These regulations relate to rules for adjusting the basis of a partner's interest in a partnership, and provide guidance for basis adjustments. The purpose of the regulation is to prevent inappropriate increases or decreases in the adjusted basis of the corporate partner's interest in a partnership resulting from the partnership's disposition of the corporate partner's stock. REG-167648-01. Published March 29, 2002.
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Determination of Basis of Partner's Interest
These regulations relate to rules for adjusting the basis of a partner's interest in a partnership, and provide guidance for basis adjustments. The purpose of the regulation is to prevent inappropriate increases or decreases in the adjusted basis of the corporate partner's interest in a partnership resulting from the partnership's disposition of the corporate partner's stock. TD 8986. Published March 29, 2002.
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Hedging Transactions
These final regulations relate to the character of gain or loss from business hedging transactions. In general, the regulations treat gain or loss on most common business hedges as ordinary rather than capital. These regulations reflect changes to the law made by the Ticket to Work and Work Incentives Improvement Act of 1999 (113 Stat. 1860). The regulations affect businesses entering into hedging transactions. TD 8985. Published March 20, 2002. Corrected May 13, 2002.
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Loss Limitation Rules
These temporary, final and proposed regulations under sections 337(d) and 1502 of the Internal Revenue Code provide guidance on the treatment of certain losses recognized on sales of subsidiary stock by members of a consolidated group. The regulations apply to corporations filing consolidated returns, both during and after the period of affiliation, and also affect purchasers of the stock of members of a consolidated group. TD 8984. Published March 12, 2002.
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Loss Limitation Rules
These temporary, final and proposed regulations under sections 337(d) and 1502 of the Internal Revenue Code provide guidance on the treatment of certain losses recognized on sales of subsidiary stock by members of a consolidated group. The regulations apply to corporations filing consolidated returns, both during and after the period of affiliation, and also affect purchasers of the stock of members of a consolidated group. REG-102740-02. Published March 12, 2002.
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Application of Section 338 to Insurance Companies
These proposed regulations apply to a deemed sale or acquisition of an insurance company's assets pursuant to an election under section 338 of the Internal Revenue Code, to a sale or acquisition of an insurance trade or business subject to section 1060, and to the acquisition of insurance contracts through assumption reinsurance. It also contains proposed regulations under section 381 concerning the effect of certain corporate liquidations and reorganizations on certain tax attributes of insurance companies. The proposed regulations apply to insurance companies and to corporations selling and purchasing stock of insurance companies. REG-118861-00. Published March 8, 2002.
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Civil Cause of Action for Damages
These proposed regulations make amendments and additions to sections of the Taxpayer Bill of Rights 2 and the Internal Revenue Service Restructuring and Reform Act of 1998. Section 7433 gives taxpayers a cause of action in federal court if, in connection with the collection of any federal tax, an officer or employee of the Internal Revenue Service recklessly or intentionally disregards any provision of the Internal Revenue Code or any regulations promulgated under the Internal Revenue Code. The Taxpayer Bill of Rights 2 increased the ceiling on damages under section 7433 to $1,000,000. The IRS Restructuring Act of 1998 added new causes of action to section 7433 for the negligent disregard of the Internal Revenue Code or regulations during a collection action and for the willful violation of section 362 or 524 of the Bankruptcy Code. The 1998 act also added a new cause of action for wrongful levy. REG-107366-00. Published March 5, 2002.
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Civil Cause of Action for Certain Collections
This document withdraws the earlier notice of proposed rulemaking published on December 31, 1997, relating to provisions of the Taxpayer Bill of Rights 2 (TBOR2). The TBOR2 raised the cap on damages under section 7433 and eliminated the jurisdictional prerequisite requiring a taxpayer to exhaust administrative remedies before filing a civil damage action. REG-251502-96. Published March 4, 2002.
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Page Last Reviewed or Updated: 17-Aug-2012