Internal Revenue Bulletin:  2004-24 

June 14, 2004 

INCOME TAX


Rev. Rul. 2004-56 Rev. Rul. 2004-56

Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning July 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. 2004-58 Rev. Rul. 2004-58

Preproduction costs of creative property. This ruling provides that a taxpayer may not deduct as a loss under section 165 of the Code the costs of acquiring and developing creative property if the taxpayer does not establish an intention to abandon the property and an affirmative act of abandonment, or an identifiable event evidencing a closed and completed transaction establishing the worthlessness of the property.

Rev. Rul. 2004-59 Rev. Rul. 2004-59

State law conversion from partnership to corporation. This ruling explains the federal tax consequences when an entity classified as a partnership for federal tax purposes converts into a state law corporation under a state statute that does not require an actual transfer of the unincorporated entity’s assets or interests.

T.D. 9127 T.D. 9127

Final and temporary regulations under section 108 of the Code clarify that if a taxpayer realizes excluded COD income either during or after the taxable year in which the taxpayer is the distributor or transferor of assets for a transaction described in section 381(a), those attributes to which the acquiring corporation succeeds, including the basis of property, must reflect the reductions required by section 108(b).

T.D. 9129 T.D. 9129

Final, temporary, and proposed regulations under section 263A of the Code except interest expense incurred by a lessor in certain safe harbor leasing transactions from the requirement to capitalize interest under section 263A.

REG-148399-02 REG-148399-02

Final, temporary, and proposed regulations under section 263A of the Code except interest expense incurred by a lessor in certain safe harbor leasing transactions from the requirement to capitalize interest under section 263A.


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