Internal Revenue Bulletin: 2008-48
December 1, 2008
Table of Contents
This announcement will extend the test of the Fast Track Settlement (FTS) for SB/SE Taxpayers Pilot Program for an additional two years to further evaluate the program and seek additional cases for fast track settlement.
This announcement modifies Revenue Procedures 2002-44, 2002-2 C.B. 10, and 2006-44, 2006-2 C.B. 800, by establishing a two-year test of the mediation and arbitration procedures for Offer in Compromise and Trust Fund Recovery Penalty cases that are under the jurisdiction of the Office of Appeals. Rev. Procs. 2002-44 and 2006-44 modified.
This document contains corrections to final regulations under section 1502 of the Code (T.D. 9424, 2008-44 I.R.B. 1012) that provide rules for determining the tax consequences of a member’s transfer (including by deconsolidation and worthlessness) of loss shares of subsidiary stock. The regulations also provide that section 362(e)(2) generally does not apply to transactions between members of a consolidated group.
This document cancels a public hearing on proposed regulations (REG-102822-08, 2008-38 I.R.B. 744) that provide guidance on the manner in which an S corporation reduces its tax attributes under section 108(b) for taxable years in which the S corporation has discharge of indebtedness income that is excluded from gross income under section 108(a).
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