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(ii) The return for the loss or credit year is due (without regard to extensions) after December 31 , 1989
the average annual gross receipts of the taxpayer for the 4 taxable years preceding the taxable year for which the credit is being determined (hereinafter in this subsection referred to as the "credit year").
In the case of a tax shelter item (as defined in paragraph (g)(3) of this section), a "tainted item" is any item for which there is not, with respect to the loss or credit year, both substantial authority and a reasonable belief that the tax treatment is more likely than not the proper treatment.
Except in the case of a tax shelter item (as defined in paragraph (g)(3) of this section), a "tainted item" is any item for which there is neither substantial authority nor adequate disclosure with respect to the loss or credit year.
Disclosure is adequate with respect to an item which is included in any loss, deduction or credit that is carried to another year only if made in connection with the return (or qualified amended return) for the taxable year in which the carryback or carryover arises (the "loss or credit year").
The penalty for a substantial understatement of income tax applies to any portion of an underpayment for a year to which a loss, deduction or credit is carried that is attributable to a "tainted item" for the year in which the carryback or carryover of the loss, deduction or credit arises (the "loss or credit year").
Similar(53)
This is a two credit year-long seminar with face to face meetings in the fall term ending at thanksgiving, face to face meetings in the spring term ending at spring vacation, and online connection throughout.
For two years he led a non credit year-long tutorial on "Heavy Metals and Autism". He teaches general chemistry to post-baccalaureate pre-medical students in the Harvard Extension School and Summer Schools.
Each automaker's light trucks are now required to average 20.7 miles per gallon, though there is some flexibility to carry over credits year to year.
The 6-credit, year-long course requires students to work in self-directed teams of approximately 5 to 6 members.
Bi-weekly paid staff members who retire will have time in the COB applied to credited years of service for the Employees' Retirement Plan (ERP).
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