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Article: REG-108045-08
- Article from:
- United States. Internal Revenue Bulletin
- Article date:
- October 26, 2009
- Author:
CopyrightCopyright Superintendent of Documents Oct 26, 2009. Provided by ProQuest LLC. (Hide copyright information)
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Notice of Proposed Rulemaking by Cross-Reference to Temporary Regulations
Definition of Omission from Gross Income
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking by cross-reference to temporary regulations.
SUMMARY: This document contains proposed regulations defining an omission from gross income for purposes of the six-year minimum period for assessment of tax attributable to partnership items and the six-year period for assessing tax. The regulations resolve a continuing issue as to whether an overstatement of basis in a sold asset results in an omission from gross income. The regulations will affect any taxpayer who overstates basis in a sold ...