sec

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sec

Abbreviation for second.
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Because Sec. 199 results in a deduction for qualifying taxpayers, questions began to arise shortly after the section's enactment that relate to the interplay of the deduction with other Code provisions.
Under Sec. 419(c)(3), a benefit's qualified direct cost in any year is that year's cost of providing the benefit, plus related administrative costs, based on the cash method of accounting.
Pursuant to Sec. 645, if both the executor (if any) of an estate and the trustee of a qualified revocable trust so elect, the "electing" trust--a qualified revocable trust (QRT) that makes the Sec.
The TIPRA made significant changes to the Sec. 355 spinoff rules.
We suggest two ways to help IRC Secs. 1202 and 1045-related issues result in positive client interactions.
* The Service issued additional guidance on the interpretation of plans under Sec. 355(e) and elections under new Sec.
In the past year, Treasury issued final regulations (4) on a partnership's obligation to withhold tax on effectively connected taxable income allocable to a foreign partner under Sec. 1446.
The Tax Court held that TLC was subject to the Sec. 274(n) limit on per-diem meal expense allowances it paid to the drivers, because it was the driver's common-law employer (see Transport Labor Contract /Leasing, Inc., 123 TC 154 (2004)).
In most transactions, the amount of ordinary income recognized under Sec. 1245 for an item of property equals the lesser of the gain on the particular item of Sec.