Technical Explanation of the Tax Simplification Act of 1991 (H.R. 2777 And S. 1394) Jcx-8-91
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To quickly assess the difficulty of the text, read a short excerpt:
In addition, the bill provides a special rule to address the factual situation presented in Munro .
Specifically, the bill provides a declaratory judgment procedure in the Tax Court for adjustments to an oversheltered return. An oversheltered return is a return that shows no taxable income and a net loss from TEFRA partnerships. In such a case, the IRS is authorized to issue a notice of adjustment with respect to non-TEFRA items, notwithstanding that no deficiency would result from the adjustme...nt. However, the IRS may only issue such a notice if a deficiency would have arisen in the absence of the net loss from TEFRA partnerships.
The Tax Court would be granted jurisdiction to determine the correctness of such an adjustment. No tax would be due upon such a determination, but a decision of the Tax Court would be treated as a final decision, permitting an appeal of the decision by either the taxpayer or the IRS. An adjustment determined to be correct would thus have the effect of increasing the taxable income that would be deemed to have been reported on the taxpayer's return.
What to read after Technical Explanation of the Tax Simplification Act of 1991 (H.R. 2777 And S. 1394) Jcx-8-91?
You can find similar books in the "Read Also" column, or choose other free books by United States. Congress. Joint Committee On Taxation to read onlineMoreLess
To quickly assess the difficulty of the text, read a short excerpt:
In addition, the bill provides a special rule to address the factual situation presented in Munro .
Specifically, the bill provides a declaratory judgment procedure in the Tax Court for adjustments to an oversheltered return. An oversheltered return is a return that shows no taxable income and a net loss from TEFRA partnerships. In such a case, the IRS is authorized to issue a notice of adjustment with respect to non-TEFRA items, notwithstanding that no deficiency would result from the adjustme...nt. However, the IRS may only issue such a notice if a deficiency would have arisen in the absence of the net loss from TEFRA partnerships.
The Tax Court would be granted jurisdiction to determine the correctness of such an adjustment. No tax would be due upon such a determination, but a decision of the Tax Court would be treated as a final decision, permitting an appeal of the decision by either the taxpayer or the IRS. An adjustment determined to be correct would thus have the effect of increasing the taxable income that would be deemed to have been reported on the taxpayer's return.
What to read after Technical Explanation of the Tax Simplification Act of 1991 (H.R. 2777 And S. 1394) Jcx-8-91?
You can find similar books in the "Read Also" column, or choose other free books by United States. Congress. Joint Committee On Taxation to read onlineMoreLess
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