Any method that does allocate
costs to specific inventory items may be compared to any other permissible method that allocates
costs to specific inventory items to determine reasonableness (this is hardly ever the case).
A donor therefore cannot allocate
GST exemption to a grantor retained annuity trust or qualified personal residence trust--where the trust property is included in her gross estate if she dies before her retained interest in the trust terminates--until the estate tax inclusion period ends (when the grantor dies, a generation-skipping transfer occurs with respect to the property, or the grantor's retained interest in the trust expires).
162-29(c)(6) should be revised to state that the taxpayer must allocate
the travel costs to lobbying only if a substantial purpose of the trip was for lobbying.
Under a traditional ESOP, an ESOP trust borrows money to buy stock, holds the stock as collateral in a suspense account and allocates
it over the term of the loan according to one of the formulas Treasury regulations permit.
Because it is impracticable (or impossible) to trace and allocate
each individual discount through the system, some sort of allocation method should be allowed as long as such method clearly reflects income and is consistently applied.
Notwithstanding paragraph (e)(12)(ii), a taxpayer shall allocate
a deduction for a charitable contribution solely to United States gross income if the contribution is made to an [U.
While the rules probably do correct the failure to properly allocate
the exemption to trusts meant to benefit skip persons, they can also result in wasting the GST exemption, by automatically allocating it to trusts not intended to benefit skip persons.
If a taxpayer has a loss in a separate limitation category in a noncontrolled section 902 company as a result of interest expense apportionment it may elect to allocate
interest expense to any other separate limitation category that is in an excess credit position.
the BIG or BIL to the contributing partner.
Thus, when a partnership interest is exchanged for debt, the partnership must recognize cancellation of debt income and allocate
it to its historical partners.
On first consideration, it might appear appropriate to simply allocate
aggregate preliminary materiality in proportion to the balances of the various financial statement elements.
Larry and the retail sales corporation could allocate
more of the sales price to the land to increase the portion of the gain that is capital gain.