26 C.F.R. § 1.1502-80T   Applicability of other provisions of law (temporary).


Title 26 - Internal Revenue


Title 26: Internal Revenue
PART 1—INCOME TAXES
Administrative Provisions and Other Rules

Browse Previous |  Browse Next

§ 1.1502-80T   Applicability of other provisions of law (temporary).

(a) and (b) [Reserved]. For further guidance, see §1.1502–80(a) and (b).

(c) Deferral of section 165. Stock of a member is not treated as worthless under section 165 before the stock is treated as disposed of under the principles of §1.1502–19(c)(1)(iii). If stock of a member would otherwise be treated as worthless under the principles of section 165, then, notwithstanding the previous sentence, such stock may be treated as worthless under section 165 immediately prior to the time such member ceases to be a member of the group. See §§1.1502–11(d) and 1.1502–35 for additional rules relating to stock loss. This paragraph (c) applies to taxable years beginning after March 18, 2004 and before March 19, 2007. Taxpayers, however, may apply this paragraph (c) to taxable years beginning on or after January 1, 1995 and before March 18, 2004; otherwise, paragraph (c) of §1.1502–80 as contained in 26 CFR part 1 edition revised as of April 1, 2003, shall apply to taxable years beginning on or after January 1, 1995, and on or before March 18, 2004.

(d) through (f) [Reserved]. For further guidance, see §1.1502–80(d) through (f).

[T.D. 9118, 69 FR 12801, Mar. 18, 2004, as amended by T.D. 9192, 70 FR 14411, Mar. 22, 2005; T.D. 9254, 71 FR 13018, Mar. 14, 2006]

Browse Previous |  Browse Next


chanrobles.com