Internal Revenue Bulletin:  2005-13 

March 28, 2005 

INCOME TAX


Rev. Rul. 2005-16 Rev. Rul. 2005-16

Low-income housing credit; satisfactory bond; “bond factor” amounts for the period January through June 2005. This ruling announces the monthly bond factor amounts to be used by taxpayers who dispose of qualified low-income buildings or interests therein during the period January through June 2005.

Rev. Rul. 2005-22 Rev. Rul. 2005-22

LIFO; price indexes; department stores. The January 2005 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, January 31, 2005.

T.D. 9186 T.D. 9186

Temporary and proposed regulations under section 6664 of the Code provide additional circumstances that end the period within which a taxpayer may file an amended return that constitutes a qualified amended return. The regulations provide that the period for filing a qualified amended return is terminated once the IRS has served a John Doe summons on a third party with respect to the taxpayer’s tax liability. In addition, for taxpayers who have claimed tax benefits from undisclosed listed transactions, the regulations provide that the period for filing a qualified amended return is terminated once the IRS contacts a promoter, organizer, seller, or material advisor concerning the listed transaction. The regulations also provide that the date on which published guidance is issued announcing a settlement initiative for a listed transaction in which penalties are compromised or waived is an additional date by which a taxpayer must file a qualified amended return. Notice 2004-38 obsoleted.

T.D. 9186 T.D. 9186

Temporary and proposed regulations under section 6664 of the Code provide additional circumstances that end the period within which a taxpayer may file an amended return that constitutes a qualified amended return. The regulations provide that the period for filing a qualified amended return is terminated once the IRS has served a John Doe summons on a third party with respect to the taxpayer’s tax liability. In addition, for taxpayers who have claimed tax benefits from undisclosed listed transactions, the regulations provide that the period for filing a qualified amended return is terminated once the IRS contacts a promoter, organizer, seller, or material advisor concerning the listed transaction. The regulations also provide that the date on which published guidance is issued announcing a settlement initiative for a listed transaction in which penalties are compromised or waived is an additional date by which a taxpayer must file a qualified amended return. Notice 2004-38 obsoleted.

T.D. 9187 T.D. 9187

Final regulations under sections 337(d) and 1502 of the Code disallow certain losses recognized on sales of subsidiary stock by members of a consolidated group. The regulations apply to corporations filing consolidated returns and to purchasers of stock of members of a consolidated group.

REG-148701-03 REG-148701-03

Proposed regulations under section 6502 of the Code incorporate the changes imposed by the IRS Restructuring and Reform Act of 1988 that limit the IRS’s ability to enter into agreements extending the statute of limitations for collection. The regulations also incorporate a provision governing the continued effect of collection statute extension agreements executed prior to January 1, 2000.

Notice 2005-27 Notice 2005-27

This notice discusses the proper exchange rate to be used under the dollar approximate separate transactions method (DASTM) of regulations section 1.985-3(d) to translate certain types of assets transferred from a qualified business unit to its U.S. home office.

Notice 2005-28 Notice 2005-28

This notice extends the deadline by which state and local governments must nominate projects for designation by the Secretary as qualified green building and sustainable design projects under section 142(l) of the Code.

Notice 2005-29 Notice 2005-29

Transition relief for certain partnerships and other pass-thru entities under section 470. This notice provides transition relief under section 470 of the Code to partnerships and other pass-thru entities that are treated as holding tax-exempt use property because of the application of section 168(h)(6).


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