26 C.F.R. § 7.465-4 Insufficient records.
Title 26 - Internal Revenue
If sufficient records do not exist to accurately determine under §7.465–2 the amount which a taxpayer is at risk on the effective date, the amount at risk shall be the taxpayer's basis in the activity reduced (but not below zero) by the taxpayer's share of amounts described in section 465(b) (3) or (4) with respect to the activity on the day before the effective date. [T.D. 7504, 42 FR 42198, Aug. 22, 1977]
Title 26: Internal Revenue
PART 7—TEMPORARY INCOME TAX REGULATIONS UNDER THE TAX REFORM ACT OF 1976
§ 7.465-4 Insufficient records.