Internal Revenue Bulletin: 2004-21
May 24, 2004
Table of Contents
Partnerships; amortization of intangibles. This ruling provides that if a section 197(f)(9) intangible is amortizable in the hands of a partnership, the anti-churning rules under section 1.197-2(h)(12)(vii)(A) of the regulations do not apply to curative or remedial reverse section 704(c) allocations of amortization. It also provides that if a section 197(f)(9) intangible was not amortizable in the hands of the partnership, then remedial, not curative, reverse section 704(c) allocations of amortization are permitted.
Section 1504. This notice announces circumstances in which the failure to satisfy the value requirement of section 1504(a)(2)(B) of the Code will be disregarded under section 1504(a)(5)(C) and (D) in determining whether a corporation is treated as a member of an affiliated group. The notice also announces that regulations will be proposed and invites comments.
This notice announces that the Service and the Treasury Department will issue temporary and proposed regulations that will modify the definition of “qualified amended return” in regulations section 1.6664-2(c)(3).
This announcement is a settlement initiative for taxpayers to resolve transactions described in Notice 2000-44, 2000-2 C.B. 255, and substantially similar transactions (Son of Boss transactions).
This document contains corrections to temporary regulations (T.D. 9118, 2004-15 I.R.B. 718) under section 337 of the Code that clarify that in computing the amount of stock loss attributable to the recognition of built-in gain, gain recognized on the disposition of an asset may be reduced by expenses directly attributable to the recognition of that gain.
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