References in periodicals archive ?
They side-step difficult issues such as how section 274(e)(2) relates to such matters as the rules pertaining to entertainment facilities under section 274(a)(1)(B) and the other disallowance provisions within section 274, as well as the valuation of fringe benefits.
The government believes that the duplicated loss aspect of the loss disallowance rule is a valid regulation.
"The disallowances were issued because the Approved Budget for the Contract and the Contract cost were higher than the COA Evaluated Cost based on the evaluation of the contract documents by the TechITS," the COA-CP headed by COA Chairman Michael Aguinaldo noted.
291(a)(3) provides a 20% deduction disallowance for any "financial institution preference item." Sec.
TEI recommends that the FASB confirm that in applying FAS 5 to tax liabilities an enterprise need not accrue a loss for the potential disallowance of a tax position (regardless of the level of confidence that the position would be sustained if challenged) unless it is probable that the position will be challenged and disallowed by the relevant taxing authority.
The COA then tasked the PTV4 to submit the documents immediately or risk a notice of disallowance.
Also subjected to a notice of disallowance was the P291.4 million disbursements for "overpriced procurement of lotto paper supplies from TMA Pty.
This comes as the COA lifted the notice of disallowance that covered LTO's purchase of 300,000 license plates for cars and 400,000 license plates for motorcycles totaling P477,901,329.
* Disallowance of certain partnership loss transfers (Notice 2005-32).
Commissioner (1) found themselves empowered to write guidance implementing the new deduction disallowance with respect to such expenses.
However, because of the 2% limit on these deductions, the overall limit on total itemized deductions, and the disallowance of miscellaneous itemized deductions in computing minimum taxable income, the IRS determined a deficiency of $55,037, which included a $17,198 minimum tax liability.
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