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Anti-Avoidance and Anti-Loss “Background and Explanation of Provi knowledge of the revocation of the ruling
Reimportation Rules sions” paragraph 2, line 6 from the bottom or determination letter, (2) was aware that
Applicable Following a of the column, the language “the loss reim such revocation was imminent, or (3) was
portation rule is also” is corrected to read in part responsible for or was aware of the
Loss on Disposition of Stock “the anti-loss reimportation rule is also”. activities or omissions of the organization
of Consolidated Subsidiaries; 2. On page 17805, column 2, in the that brought about this revocation.
Correction preamble, under the paragraph heading If on the other hand a suit for declara
“Special Analyses”, line 5 from the top tory judgment has been timely filed, con
Announcement 2007–50 of the column, the language “U.S.C. tributions from individuals and organiza
553(b)(B) that prior notice and” is cor tions described in section 170(c)(2) that
AGENCY: Internal Revenue Service rected to read “U.S.C. 553(b)(3)(B) that are otherwise allowable will continue to
(IRS), Treasury. prior notice and”. be deductible. Protection under section
3. On page 17805, column 2, in the pre 7428(c) would begin on May 29, 2007, and
ACTION: Correction to final and tempo
amble, under the paragraph heading “Spe would end on the date the court first deter
rary regulations.
cial Analyses”, line 16 from the top of the mines that the organization is not described
SUMMARY: This document contains column, the language “reference notice of in section 170(c)(2) as more particularly
corrections to final and temporary regu the proposed” is corrected to read “refer set forth in section 7428(c)(1). For indi
lations (T.D. 9322, 2007–18 I.R.B. 1100) ence notice of proposed”. vidual contributors, the maximum deduc
that were published in the Federal Reg tion protected is $1,000, with a husband
LaNita Van Dyke, and wife treated as one contributor. This
ister on Tuesday, April 10, 2007 (71 FR
Branch Chief,
benefit is not extended to any individual, in
17804) providing guidance to corpora
Publications and Regulations Branch,
whole or in part, for the acts or omissions
tions filing consolidated returns and apply
Legal Processing Division,
of the organization that were the basis for
an anti-avoidance rule and revising an
Office of Associate Chief Counsel
revocation.
anti-loss reimportation rule that applies
(Procedure and Administration).