Internal Revenue Bulletins  

2002 Regulations

"Regulations" are the IRS Commissioner's rules, approved by the Secretary of the Treasury, or the Secretary's delegate, for the application and administration of the Internal Revenue laws. The purpose of regulations is to provide taxpayers, their representatives, and Service personnel with rules of general application so they may clearly understand the taxpayer's rights and duties under the law.

For more information about Regulations, see the Guide to Understanding the Differences Among Official IRS Documents

Regulations are in the Adobe Acrobat PDF format. Internal Revenue Bulletin Summary pages are in HTML format.

Regulation Bulletin Date of IRB Cross-Ref
REG-251003-96(PDF, 120K) IRB #2002-49(HTML) Dec. 9, 2002

N/A

This document amends the Statement of Procedural Rules to reflect changes effected by the Electronic Freedom of Information Act Amendments of 1996, to update organizational titles and addresses, and to make certain changes in the IRS's procedures for processing Freedom of Information Act (FOIA) requests. These amendments conform to procedures set forth in the Department of the Treasury's regulations on disclosure of records under the FOIA. The rules affect persons requesting records from the IRS.
REG-248110-96(PDF, 42K) IRB #2002-26(HTML) July 1, 2002

N/A

Proposed regulations under section 817A of the Code affect insurance companies that define the interest rate to be used with respect to certain insurance contracts that guarantee higher returns for an initial, temporary period. Specifically, the proposed regulations define the appropriate interest rate to be used in the determination of tax reserves and required interest for certain modified guaranteed contracts. The proposed regulations also address how temporary guarantee periods that extend past the end of a taxable year are to be taken into account. A public hearing is scheduled for August 27, 2002.
REG-209116-89(PDF, 16K) IRB #2002-47(HTML) Nov. 25, 2002

N/A

Withdrawal of requirement of making quarterly payments of the railroad unemployment repayment tax. In prior years, a repayment tax was levied on wages to repay certain loans to the railroad unemployment fund. Sections 3321 and 3322 of the Code provided for the time and manner of making these payments. Any loans which applied to this repayment tax have been fully repaid. Thus, the requirement is no longer relevant. EE-79-89 withdrawn.
REG-209114-90(PDF, 198K) IRB #2002-9(HTML) March 4, 2002

N/A

Proposed regulations under section 280G of the Code provide guidance about the denial of the deduction to a corporation for any excess golden parachute payment to certain individuals.
REG-167648-01(PDF, 21K) IRB #2002-16(HTML) April 22, 2002

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Proposed regulations under section 705 of the Code provide guidance for making basis adjustments necessary to coordinate sections 705 and 1032 in situations in which a corporation owns a direct or indirect interest in a partnership that holds stock in that corporation.
REG-165868-01(PDF, 119K) IRB #2002-31(HTML) Aug. 5, 2002

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Proposed regulations under section 419A of the Code provide guidance regarding whether a welfare benefit plan is part of a 10-or-more employer plan described in section 419A(f)(6). A public hearing is scheduled for November 5, 2002.
REG-165706-01(PDF, 34K) IRB #2002-16(HTML) April 22, 2002

N/A

Proposed regulations modify the definition of a refunding issue under section 1.150-1(d) of the regulations in connection with a combination of section 501(c)(3) organizations. Generally, interest on bonds issued by state and local governments is excluded from gross income, however, this exclusion does not apply to certain refunding issues. A public hearing is scheduled for July 30, 2002.
REG-164754-01(PDF, 179K) IRB #2002-30(HTML) July 29, 2002

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Proposed regulations under section 61 of the Code provide comprehensive guidance on split-dollar life insurance arrangements for federal income, employment, and gift tax purposes. In general, the regulations provide two mutually exclusive regimes for the taxation of these arrangements: the economic benefit regime and the loan regime. A public hearing is scheduled for October 23, 2002.
REG-163892-01(PDF, 22K) IRB #2002-20(HTML) May 20, 2002 T.D. 8988(PDF, 22K)
Temporary and proposed regulations under section 355(e) of the Code relate to the recognition of gain on certain distributions of stock or securities of a controlled corporation in connection with an acquisition. These regulations provide guidance on whether an acquisition is part of a plan that includes the distribution. The proposed regulations withdraw REG-107566-00 (2001-1 C.B. 346).
REG-161424-01(PDF, 84K) IRB #2002-21(HTML) May 28, 2002

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Proposed regulations under section 6050S relate to information reporting, including magnetic media reporting for qualified tuition and related expenses (Form 1098-T) and the continuation of Notice 97-73 for the calendar year 2002. A public hearing is scheduled for August 13, 2002. REG-105316-98 withdrawn.
REG-159079-01(PDF, 20K) IRB #2002-6(HTML) Feb. 11, 2002 T.D. 8977(PDF, 20K)
Temporary and proposed regulations under section 1441 of the Code amend current sections of the regulations to allow withholding agents, who are also acceptance agents, to rely on a beneficial owner withholding certificate that does not contain an individual taxpayer identifying number (ITIN) in limited circumstances when the IRS is not issuing ITINs. Specifically, the amendments would have the effect of: (1) allowing certain withholding agents to obtain ITINs on an expedited basis for foreign individuals receiving unexpected payments and claiming tax treaty benefits with respect to those payments; and (2) allowing withholding agents to make unexpected payments to foreign individuals, who do not possess ITINs, when the use of the expedited process is unavailable.
REG-154920-01(PDF, 32K) IRB #2002-22(HTML) June 3, 2002

N/A

Proposed regulations under section 954 of the Code provide that gain or loss arising from certain commodities hedging transactions and currency gain or loss arising from certain interest-bearing liabilities do not constitute (or are not netted against) foreign personal holding company income.
REG-150313-01(PDF, 122K) IRB #2002-44(HTML) Nov. 4, 2002

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Proposed regulations under sections 302, 304, and other sections of the Code provide guidance regarding the treatment of the basis of redeemed stock when a distribution in redemption of such stock is treated as a dividend. The regulations also provide guidance regarding certain acquisitions of stock by related corporations that are treated as distributions in redemption of stock. A public hearing is scheduled for February 20, 2003.
REG-143321-02(PDF, 22K) IRB #2002-48(HTML) Dec. 2, 2002 T.D. 9022(PDF, 22K)
Temporary and proposed regulations under section 6043(c) of the Code require information reporting by a corporation if there is an acquisition of control of the corporation or a substantial change in the corporation's capital structure. The regulations require the corporation to file a form reporting the event and to file Forms 1099 with respect to amounts distributed to shareholders. These regulations also require brokers who receive a Form 1099 as the record holder of stock, pursuant to section 6043(c) regulations, to file a Form 1099 with respect to the actual owner of the stock. A public hearing on the proposed regulations is scheduled for March 5, 2003.
REG-142299-01, REG-209135-88(PDF, 26K) IRB #2002-4(HTML) Jan. 28, 2002 T.D. 8975(PDF, 26K)
Temporary and proposed regulations apply to certain transactions or events that result in a Regulated Investment Company (RIC) or a Real Estate Investment Trust (REIT) owning property that has a basis determined by reference to a C corporation's basis in the property. These regulations clarify the tax treatment of transfers of C corporation property to a RIC or REIT.
REG-141832-02(PDF, 23K) IRB #2002-48(HTML) Dec. 2, 2002 T.D. 9020(PDF, 23K)
Substantiation of incidental expenses. Final, temporary, and proposed regulations under section 274 of the Code authorize the Commissioner to establish a method under which a taxpayer may substantiate the amount of incidental expenses paid or incurred while traveling away from home by means of an allowance in lieu of substantiating the actual cost.
REG-136311-01(PDF, 209K) IRB #2002-36(HTML) Sept. 9, 2002

N/A

Proposed regulations explain when a foreign corporation engaged in the international operation of ships or aircraft may exclude its U.S. source income from gross income for U.S. federal income tax purposes. The rule applies if such a corporation is organized in a foreign country that grants an equivalent exemption to corporations organized in the United States, and the foreign corporation satisfies certain ownership requirements. A public hearing is scheduled for November 12, 2002. REG-208280-86 withdrawn.
REG-136193-01(PDF, 117K) IRB #2002-21(HTML) May 28, 2002

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Proposed regulations under section 4980F of the Code provide guidance on the requirements for plan administrators to give notice of plan amendments that provide for significant reduction in the rate of future benefit accrual or an early retirement benefit or retirement-type subsidy. When finalized, the regulations will affect businesses, nonprofit organizations, and individuals. A public hearing is scheduled for August 15, 2002.
REG-134026-02(PDF, 17K) IRB #2002-40(HTML) Oct. 7, 2002 T.D. 9015(PDF, 17K)
Final, temporary, and proposed regulations under section 7602 of the Code amend section 301.7602-1 of the regulations to include officers and employees of the Office of Chief Counsel in the group of persons who can take summoned testimony under oath and receive summoned documents.
REG-133254-02(PDF, 41K) IRB #2002-34(HTML) Aug. 26, 2002

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Proposed regulations under section 6049 of the Code relate to the reporting requirements for interest on deposits maintained at U.S. offices of certain financial institutions and paid to non-resident alien individuals that are residents of certain specified countries. A public hearing is scheduled for December 5, 2002. REG-126100-00 withdrawn.
REG-131478-02(PDF, 120K) IRB #2002-47(HTML) Nov. 25, 2002

N/A

Proposed regulations under section 1502 of the Code redetermine the basis of stock of a subsidiary member of a consolidated group immediately prior to certain dispositions and deconsolidations of such stock. In addition, the regulations suspend certain losses recognized on the disposition of such stock. The regulations apply to corporations filing consolidated returns. A public hearing is scheduled for January 15, 2003.
REG-127380-02(PDF, 23K) IRB #2002-50(HTML) Dec. 16, 2002

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Proposed regulations provide guidance regarding the application of section 367(e)(2) of the Code to certain outbound liquidations. The regulations amend the anti-abuse rule of section 1.367(e)-2(d) by narrowing the scope of the rule to apply only to outbound transfers to a foreign corporation in a complete liquidation of a domestic corporation in which a principal purpose of the liquidation is the avoidance of U.S. tax. A public hearing is scheduled for March 3, 2003.
REG-126024-01(PDF, 62K) IRB #2002-27(HTML) July 8, 2002

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Proposed regulations provide rules relating to the reporting of gross proceeds payments to attorneys. The regulations reflect changes to the law made by the Taxpayer Relief Act of 1997. The regulations will affect attorneys who receive payments of gross proceeds on behalf of their clients and certain payors (for example, defendents in lawsuits and their insurance companies and agents) that, in the course of their trades or businesses, make payments to these attorneys. A public hearing is scheduled for September 30, 2002.
REG-125626-01(PDF, 26K) IRB #2002-9(HTML) March 4, 2002

N/A

Unit livestock price method. Proposed regulations under section 471 of the Code provide rules relating to the annual reevaluation of unit livestock prices and the depreciation of live-stock raised for drafting, breeding, or dairy purposes. A public hearing is scheduled for June 12, 2002.
REG-125450-01(PDF, 20K) IRB #2002-5(HTML) Feb. 4, 2002

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Proposed regulations under section 4374 of the Code contain amendments to the regulations relating to liability for the insurance premium excise tax. This document affects persons who make, sign, issue, or sell a policy of insurance, indemnity bond, annuity contract, or policy of reinsurance issued by any foreign insurer or reinsurer. A public hearing is scheduled for March 19, 2002.
REG-124667-02(PDF, 70K) IRB #2002-44(HTML) Nov. 4, 2002

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Proposed regulations under section 417 of the Code would consolidate the content requirements applicable to explanations of qualified joint and survivor annuities and qualified preretirement survivor annuities payable from certain retirement plans. In addition, these regulations would specify requirements for disclosing the relative value of optional forms of benefit that are payable from certain retirement plans in lieu of a qualified joint and survivor annuity. A public hearing is scheduled for January 14, 2003.
REG-124256-02(PDF, 34K) IRB #2002-33(HTML) Aug. 19, 2002

N/A

Proposed regulations under sections 408 and 408A of the Code provide a new method for determining the earnings allocable to IRA contributions that are returned or recharacterized before the applicable tax return due date.
REG-123345-01(PDF, 23K) IRB #2002-32(HTML) Aug. 12, 2002

N/A

Proposed regulations under section 2519 of the Code relate to the amount treated as a transfer under section 2519 when there is a right to recover gift tax under section 2207A(b) of the Code and the related gift tax consequences if the right to recover the gift tax is not exercised. A public hearing is scheduled for October 15, 2002.
REG-123305-02(PDF, 24K) IRB #2002-26(HTML) July 1, 2002 T.D. 8998(PDF, 24K)
Temporary and proposed regulations under sections 337(d) and 1502 of the Code clarify and amend certain aspects of the temporary regulations relating to the deductibility of losses recognized on dispositions of subsidiary stock by members of a consolidated group. The regulations apply to corporations filing consolidated returns, both during and after the period of affiliation, and also affect purchasers of the stock of members of a consolidated group. A public hearing on the proposed regulations is scheduled for July 17, 2002.
REG-122564-02(PDF, 23K) IRB #2002-26(HTML) July 1, 2002 T.D. 8997(PDF, 23K)
Final and proposed regulations under section 1502 of the Code provide corporations filing consolidated returns with an election to waive the 5-year net operating loss carryback period with respect to certain acquired members.
REG-120135-01(PDF, 20K) IRB #2002-8(HTML) Feb. 25, 2002

N/A

Proposed regulations relate to the definition of agent for certain purposes. The regulations clarify that the term agent in certain provisions of section 6103 of the Code includes contractors.
REG-119436-01(PDF, 18K) IRB #2002-3(HTML) Jan. 22, 2002

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Temporary and proposed regulations under section 45D of the Code provide guidance on the new markets tax credit. A taxpayer making a qualified equity investment in a qualified community development entity that has received a new markets tax credit allocation may claim a 5-percent tax credit with respect to the qualified equity investment on each of the first 3 credit allowance dates and a 6-percent credit on each of the remaining 4 credit allowance dates. A public hearing on the proposed regulations is scheduled for March 14, 2002.
REG-118861-00(PDF, 100K) IRB #2002-12(HTML) March 25, 2002

N/A

Proposed regulations apply to a deemed sale or acquisition of an insurance company's assets pursuant to an election under section 338 of the Code, to a sale or acquisition of an insurance trade or business subject to section 1060, and to the acquisition of insurance contracts through assumption reinsurance. The regulations also concern the effect under section 381 of certain corporate liquidations and reorganizations on certain tax attributes of insurance companies. The regulations apply to insurance companies and to corporations selling and purchasing stock of insurance companies. A public hearing is scheduled for September 18, 2002.
REG-116644-01(PDF, 38K) IRB #2002-31(HTML) Aug. 5, 2002

N/A

Proposed regulations under sections 3406 and 6724 of the Code clarify rules with respect to notices of incorrect taxpayer identification numbers for purposes of backup withholding and waiver of information reporting penalties. A public hearing is scheduled for October 22, 2002.
REG-115781-01(PDF, 32K) IRB #2002-33(HTML) Aug. 19, 2002

N/A

Proposed regulations under section 2055 of the Code conform the income, gift, and estate tax regulations to the Tax Courtís decision in Estate of Boeshore v. Commissioner, 78 T.C. 523 (1982), acq. in result, 1987-2 C.B. 1, holding portions of section 20.2055(e)(2)(vi)(e) of the estate tax regulations invalid. Rev. Rul. 76-225 revoked. A public hearing is scheduled for October 16, 2002.
REG-115285-01(PDF, 28K) IRB #2002-27(HTML) July 8, 2002

N/A

Proposed regulations exclude certain Low-Income Taxpayer Clinics (LITCs) that qualify for grants under section 7526 of the Code from the definition of income tax return preparer under section 7701(a)(36) of the Code. These proposed regulations also exclude certain persons who are employed by, or volunteer for, such clinics.
REG-115054-01(PDF, 45K) IRB #2002-7(HTML) Feb. 19, 2002

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Proposed regulations under section 66 of the Code relate to the treatment of community income for certain married individuals in community property states who do not file joint individual federal income tax returns. The regulations also reflect changes in the law made by the Internal Revenue Service Restructuring and Reform Act of 1998.
REG-112991-01(PDF, 113K) IRB #2002-4(HTML) Jan. 28, 2002

N/A

Proposed regulations modify the following provisions of T.D. 8930: (1) that qualified research be undertaken for the purpose of discovering information that is technological in nature; (2) the process of experimentation; (3) the type of computer software constituting internal use software; (4) the first part of the three-part high threshold of innovation test for internal-use software to be excepted from the exclusion from qualified research; and (5) the documentation required to substantiate the research credit. A public hearing is scheduled for March 27, 2002.
REG-112306-00(PDF, 90K) IRB #2002-44(HTML) Nov. 4, 2002

N/A

Proposed regulations under section 1296 of the Code contain procedures for certain United States persons holding marketable stock in a passive foreign investment company (PFIC) to elect mark to market treatment for that stock. A public hearing is scheduled for November 6, 2002.
REG-108697-02(PDF, 14K) IRB #2002-19(HTML) May 13, 2002

N/A

Final, temporary, and proposed regulations under section 401 of the Code relate to required minimum distributions from qualified plans, section 457 plans, section 403(b) annuity plans, and retirement income accounts (IRAs).
REG-107524-00(PDF, 41K) IRB #2002-28(HTML) July 15, 2002

N/A

Proposed regulations define whether an organization has a significant trade or business of lending money under section 6050P of the Code for purposes of reporting discharges of indebtedness. A public hearing is scheduled for October 8, 2002.
REG-107366-00(PDF, 51K) IRB #2002-12(HTML) March 25, 2002

N/A

Proposed regulations under section 7433 of the Code relate to civil causes of action for damages caused by unlawful collection actions of officers and employees of the IRS and the awarding of costs and certain fees. The regulations reflect amendments made by the Taxpayer Bill of Rights 2 and the IRS Restructuring and Reform Act of 1998.
REG-107184-00(PDF, 20K) IRB #2002-20(HTML) May 20, 2002 T.D. 8989(PDF, 20K)
Final, temporary, and proposed regulations are designed to eliminate regulatory impediments to the electronic filing of Form 1040, U.S. Individual Income Tax Return.
REG-107100-00(PDF, 18K) IRB #2002-7(HTML) Feb. 19, 2002 T.D. 8981(PDF, 18K)
Final, temporary and proposed regulations under sections 874 and 882 of the Code relate to the disallowance of deductions and credits for nonresident alien individuals and foreign corporations that fail to file a timely U.S. income tax return unless the Commissioner waives the filing deadlines. The temporary regulations revise the waiver standard. A public hearing on the proposed regulations is scheduled for June 3, 2002.
REG-106879-00(PDF, 34K) IRB #2002-34(HTML) Aug. 26, 2002

N/A

Proposed regulations under section 1503(d) of the Code provide guidance regarding the events that require the recapture of dual consolidated losses. The regulations generally provide that certain events will not require recapture of a dual consolidated loss and provide for the reporting of certain information in such cases. This document also proposes certain conforming changes to the current regulations. A public hearing is scheduled for December 3, 2002.
REG-106876-00(PDF, 74K) IRB #2002-34(HTML) Aug. 26, 2002

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Proposed regulations under sections 897 and 1445 of the Code require the use of taxpayer identifying numbers on submissions. The regulations are necessary to properly identify submissions made by foreign taxpayers for the reduction or elimination of tax under these sections. The regulations also address miscellaneous items such as the amendment to section 1445(e)(3) under the Small Business Job Protection Act of 1996. A public hearing is scheduled for November 13, 2002.
REG-106871-00(PDF, 149K) IRB #2002-30(HTML) July 29, 2002

N/A

Proposed regulations under section 671 of the Code define widely held fixed investment trusts, clarify the reporting obligations of the trustees and middlemen connected with these trusts, and provide for the communication of necessary tax information to beneficial owners. REG-209813-96 withdrawn.
REG-106457-00(PDF, 30K) IRB #2002-26(HTML) July 1, 2002

N/A

Proposed regulations under section 4081 of the Code relate to the definition of diesel fuel and the application of the tax on blended taxable fuel.
REG-106359-02(PDF, 60K) IRB #2002-34(HTML) Aug. 26, 2002

N/A

Proposed regulations under section 482 of the Code clarify that stock-based compensation is taken into account in determining the intangible development costs of a controlled participant in a qualified cost sharing arrangement. The regulations also provide rules for measuring the cost associated with stock-based compensation; clarify that stock-based compensation is appropriately taken into account as a comparability factor for purposes of the comparable profits method; and clarify the coordination of the cost sharing rules with the armís length standard. A public hearing is scheduled for November 20, 2002.
REG-105885-99(PDF, 166K) IRB #2002-23(HTML) June 10, 2002

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Proposed regulations under section 457 of the Code would provide guidance on compensation deferred under eligible section 457 deferred compensation plans of state and local governmental employers and tax-exempt entities. The regulations reflect changes made to section 457 by the Tax Reform Act of 1986, the Small Business Job Protection Act of 1996, the Economic Growth and Tax Relief Reconciliation Act of 2001, and other legislation. These regulations would also make various technical changes and clarifications to the existing final regulations. A public hearing is scheduled for August 28, 2002.
REG-105369-00(PDF, 47K) IRB #2002-18(HTML) May 6, 2002

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Proposed regulations under sections 148 and 141 of the Code provide guidance on the definitions of investment-type property and private loan for the arbitrage and private activity restrictions applicable to tax-exempt bonds issued by state and local governments. A public hearing is scheduled for September 24, 2002. REG-113526-98 withdrawn.
REG-105344-01(PDF, 20K) IRB #2002-2(HTML) Jan. 14, 2002 T.D. 8968(PDF, 20K)
Temporary and proposed regulations under section 6103 of the Code permit the IRS to authorize federal, state, and local agencies with access to returns and return information to redisclose returns and return information, with the Commissioner's approval, to any authorized recipient set forth in section 6103, subject to the same conditions and restrictions, and for the same purposes, as if the recipient had received the information from the IRS directly.
REG-104762-00(PDF, 26K) IRB #2002-18(HTML) May 6, 2002

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Proposed regulations under section 6331 of the Code provide for the prohibition of levy while an installment agreement is pending with the Secretary, while an installment agreement is in effect, and following the rejection or termination of an installment agreement. The regulations clarify when levy is prohibited and the effect of that prohibition on the statute of limitations for collection. They also provide that the IRS may not commence a proceeding in court for the collection of a tax included in a proposed or active installment agreement while levy is prohibited by this section.
REG-103829-99(PDF, 36K) IRB #2002-27(HTML) July 8, 2002

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Proposed regulations under section 4051 of the Code relate to the definition of a highway vehicle for purposes of various excise taxes.
REG-103823-99(PDF, 110K) IRB #2002-27(HTML) July 8, 2002

N/A

Proposed regulations under section 167(g) of the Code relate to deductions available to taxpayers using the income forecast method of depreciation. A public hearing is scheduled for September 4, 2002.
REG-103777-02(PDF, 36K) IRB #2002-47(HTML) Nov. 25, 2002

N/A

Proposed regulations under section 7122 of the Code provide for the imposition of a $150.00 user fee for the processing of offers to compromise. The charging of user fees implements the Independent Offices Appropriations Act, 31 U.S.C. section 9701. The proposed user fee would not apply to offers based on doubt as to liability, offers made by low income taxpayers, offers accepted to promote effective tax administration, and offers accepted based on doubt as to collectibility where there has been a determination that, although an amount greater than the amount offered could be collected, collection of more than the amount offered would create economic hardship within the meaning of regulations section 301.6343-1.
REG-103736-00(PDF, 29K) IRB #2002-45(HTML) Nov. 12, 2002 T.D. 9018(PDF, 29K)
Temporary and proposed regulations under section 6112 of the Code modify the requirement for sellers and organizers to maintain lists or persons in potentially abusive tax shelters. A public hearing on the proposed regulations is scheduled for December 11, 2002.
REG-103735-00(PDF, 29K) IRB #2002-45(HTML) Nov. 12, 2002 T.D. 9017(PDF, 29K)
Temporary and proposed regulations under section 6011 of the Code modify the disclosure requirements relating to reportable transactions. Six new provisions are added pursuant to section 6011 requiring the disclosure of listed transactions that are related to estate, gift, employment, and pension and exempt organizations excise tax. A public hearing on the proposed regulations is scheduled for December 11, 2002.
REG-103735-00, REG-110311-98(PDF, 29K) IRB #2002-28(HTML) July 15, 2002 T.D. 9000(PDF, 29K)
Final, temporary, and proposed regulations under sections 6011, 6111, and 6112 of the Code modify the disclosure, registration, and list maintenance requirements relating to tax shelters.
REG-102740-02(PDF, 19K) IRB #2002-13(HTML) April 1, 2002

N/A

Temporary, final, and proposed regulations under sections 337(d) and 1502 of the Code permit certain losses recognized on sales of subsidiary stock by members of a consolidated group. The regulations apply to corporations filing consolidated returns, both during and after the period of affiliation, and also affect purchasers of the stock of members of a consolidated group. A public hearing on the proposed regulations.

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