1060, which requires buyers and sellers of a going business to allocate
values to the various assets exchanged according to the residual method.
It is essential to be aware that a rental agreement that states only when rent is payable does not specifically allocate
rent within the meaning of the regulations.
Recent audit activity indicates the IRS will require taxpayers to use one of the simplified methods (SPM or SRM) when it determines that a taxpayer is using a facts-and-circumstances method that does not allocate
costs to specific inventory items.
Compensation expense if the company allocates
the dividends to participants' accounts or if it pays them to participants out of a suspense account.
affiliated group must allocate
interest as a fungible expense on the basis of its worldwide assets.
Thus, without a consistency requirement, a trustee's decision to allocate
capital gain from year to year could be purely tax-motivated.
An allocation method that reflects benefits received from the group effort is one that allocates
joint costs in direct proportion to a segment's actual cost savings.
partnerships is their ability to allocate
items of income, gain, loss and deduction among the partners in ratios that differ from those in the partners' capital accounts.
European and other delegations at the International Telecommunications Union's (ITU) World Radio Conference (WRC) to allocate
455 MHz of unlicensed spectrum in the 5-GHz band for global WLAN use.
electricity, HVAC, and natural gas charges back to all of Easton's tenants on a monthly basis.
In their submissions with the request for technical advice, the agent and the taxpayer disagreed about how the taxpayer allocates
cost pools under this system.
The act allocates
trust receipts and disbursements between principal and income (CPC secs.