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Except in the case of any item attributable to a tax shelter (as defined in paragraph (g)(2) of this section), an understatement is reduced by the portion of the understatement that is attributable to the tax treatment of an item for which there is substantial authority, or with respect to which there is adequate disclosure.
For purposes of paragraph (e)(2)(i) of this section, a corporation will not be treated as having a reasonable basis for its tax treatment of an item attributable to a multi-party financing transaction entered into after August 5 , 1997 if the treatment does not clearly reflect the income of the corporation.
Similar(58)
This section shall be applied separately with respect to items attributable to each publicly traded partnership (and subsection (i) shall not apply with respect to items attributable to any such partnership).
Disclosure in the case of items attributable to a pass-through entity (pass-through items) is made with respect to the return of the entity, except as provided in this paragraph (f)(5).
For purposes of this section, a regulated investment company (as defined in section 851) holding an interest in a qualified publicly traded partnership (as defined in section 851(h)) shall be treated as a taxpayer described in subsection (a)(2) with respect to items attributable to such interest.
In the case of tax shelter items attributable to a pass-through entity, the actions described in paragraphs (g)(4)(i)(A) and (B) of this section, if taken by the entity, are deemed to have been taken by the taxpayer and are considered in determining whether the taxpayer reasonably believed that the tax treatment of an item was more likely than not the proper tax treatment.
Initially, the test consisted of items attributable to the following four mathematical key concepts: 1. Quantity, i.e., all approaches involving the use of numbers to describe and organize situations, to understand magnitude, and to recognize numerical patterns.
A number of studies have been conducted to estimate different cost items attributable to schizophrenia and its management [ 6- 12].
Active vasculitis was defined as a score greater than zero for PVAS items attributable to vasculitis that newly appeared or worsened during the preceding four weeks, and for which other causes such as infection were excluded [ 16, 24].
The Other Banking segment includes leasing operations and other items not attributable to any particular business segment of the bank.
Subject to subclause (III), the Secretary shall distribute to each Indian tribe that meets the criteria described in item (aa)(AA) a share of funding under this subparagraph in proportion to the share of the combined amount determined under item (aa)(BB) attributable to such Indian tribe.
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com