Internal Revenue Bulletin: 2006-4
January 23, 2006
Final and temporary regulations under section 7701 of the Code make additions to the list of foreign business entities that are always classified as corporations, per se corporations, and, therefore, are not eligible to check the box to change their classification.
This notice provides information to payees/filers who receive payments of interest on qualified education loans who are unable to comply with the reporting requirements for loan origination fees and capitalized interest under section 6050S of the Code and the regulations for calendar year 2005 returns. The notice explains that a payee/filer who is unable to comply with the reporting requirements for loan origination fees and capitalized interest may request that the Service waive, upon a showing of reasonable cause under section 6724 and the regulations, any penalty that might otherwise be imposed under sections 6721 or 6722 for failure to report these amounts.
Use of replacement cost method to value parts inventory of heavy equipment dealers. Heavy equipment dealers may approximate the cost of their heavy equipment parts inventory using the safe harbor replacement cost method described in this revenue procedure. Procedures are provided for heavy equipment dealers to obtain the automatic consent of the Commissioner to change to this replacement cost method of accounting. Rev. Proc. 2002-9 modified and amplified. Rev. Proc. 2002-17 modified.
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