SJSU BUS 223A - Summarizing Practice (17 pages)

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Summarizing Practice



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Summarizing Practice

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Pages:
17
School:
San Jose State University
Course:
Bus 223a - Tax Research and Decision Making
Tax Research and Decision Making Documents

Unformatted text preview:

Summarizing Practice A key part of writing research memos Also see Reminders on Presenting Your Own Work on 223A Website Rev Rul 92 16 1992 1 CB 15 Full text Facts Title IV of the Clean Air Act Amendments of 1990 42 U S C section 7651 et seq establishes a program of sulfur dioxide emission allowances to be allocated annually to certain electricity generating companies utilities commencing in 1995 This program will be administered by the Environmental Protection Agency Full text Holding The allocation of emission allowances by the Environmental Protection Agency and their receipt by a utility pursuant to 42 U S C section 7651b a does not cause the utility to realize gross income under section 61 of the Internal Revenue Code Accordingly under section 1012 of the Code a utility s basis in those emission allowances is not measured by reference to the fair market value of the allowances What should go into a summary of Rev Rul 92 16 Write a summary with a classmate IRC 163 h 1 2 h Disallowance of deduction for personal interest 1 In general In the case of a taxpayer other than a corporation no deduction shall be allowed under this chapter for personal interest paid or accrued during the taxable year 163 h 2 h 2 Personal interest For purposes of this subsection the term personal interest means any interest allowable as a deduction under this chapter other than A interest paid or accrued on indebtedness properly allocable to a trade or business other than the trade or business of performing services as an employee B any investment interest within the meaning of subsection d C any interest which is taken into account under section 469 in computing income or loss from a passive activity of the taxpayer D any qualified residence interest within the meaning of paragraph 3 E any interest payable under section 6601 on any unpaid portion of the tax imposed by section 2001 for the period during which an extension of time for payment of such tax is in effect under section 6163 and



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