Internal Revenue Bulletin:  2003-52 

December 29, 2003 

INCOME TAX


Rev. Rul. 2003-125 Rev. Rul. 2003-125

Worthless security deduction. This ruling discusses when a shareholder is, and is not, allowed a worthless security deduction under section 165(g)(3) of the Code when an election is made to change the federal tax classification of an entity from a corporation to a disregarded entity. Rev. Rul. 70-489 superseded and Rev. Rul. 59-296 amplified.

Rev. Rul. 2003-126 Rev. Rul. 2003-126

Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning January 1, 2004, will be 4 percent for overpayments (3 percent in the case of a corporation), 4 percent for underpayments, and 6 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 1.5 percent.

Rev. Rul. 2003-127 Rev. Rul. 2003-127

Hedge identification. This ruling holds that for purposes of the income timing rules in regulations section 1.446-4, the hedging transaction definition in section 1.1221-2(b) is not modified by section 1.1221-2(g)(2), which deals with the effects on income characterization of a mis-identification or failure to identify a hedging transaction. If a taxpayer has used a method of accounting for a type of hedging transaction but, under section 1.446-4, that method is impermissible for those transactions, the taxpayer must obtain the Commissioner's consent before changing to a method of accounting that is permitted.

Rev. Rul. 2003-128 Rev. Rul. 2003-128

LIFO; price indexes; department stores. The October 2003 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, October 31, 2003.

T.D. 9098 T.D. 9098

REG-153319-03

Temporary and proposed regulations under section 1502 of the Code amend proposed regulations (REG-132760-03, 2003-43 I.R.B. 933) and temporary regulations (T.D. 9089, 2003-43 I.R.B. 906). These regulations provide guidance concerning how a corporation that is a member of a consolidated group reduces its tax attributes when that member realizes discharge of indebtedness income that is excluded from gross income under section 108.


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