Internal Revenue Bulletin:  2007-46 

November 13, 2007 

INCOME TAX


Ct. D. 2083 Ct. D. 2083

Levies upon third party property to collect taxes owed by another; wrongful levy action. The Supreme Court holds that the Trust missed section 7426(a)(1)’s deadline for challenging a levy, and may not bring the challenge as a tax refund claim under section 1346(a)(1).

REG-140206-06 REG-140206-06

Proposed regulations under section 1441 of the Code provide guidance regarding the withholding and reporting obligations of a withholding agent in the case of a self tender by a publicly traded corporation, when a determination is required under section 301 as to whether the distribution is treated as a dividend or a distribution in part or full payment in exchange for stock. A public hearing is scheduled for February 6, 2008.

REG-114125-07 REG-114125-07

Proposed regulations under section 861 of the Code contain changes to existing final regulations regarding the source of compensation for labor or personal services.

Notice 2007-86 Notice 2007-86

This notice provides additional transition relief, under section 409A of the Code, that was scheduled to expire on December 31, 2007. Generally, this notice extends relief to December 31, 2008, except that reliance on the proposed regulations under section 409A is not permitted after December 31, 2007. Notice 2007-78 modified. Section 3 of Notice 2006-79 modified and superseded.

Notice 2007-88 Notice 2007-88

This notice requests public comment on a proposal to change the process by which taxpayers obtain the consent of the Commissioner of Internal Revenue to change a method of accounting for federal income tax purposes.


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