Ratable

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Ratable

1. Describing a property of which an appraisal is possible. For example, a farm is a ratable property because its value is able to be assessed.

2. See: Taxable.

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Clearly, the ratable allocation rule prescribed in section 382(b)(3) for an ownership change that does not trigger an automatic closing of the year is a rule of administrative convenience.

Proposed section 382 regulations

Examples 2 and 3 demonstrate the differing results that may be obtained if a loss corporation elects a closing of the books rather than a daily ratable allocation.

382 limitation 200,000 Prechange income 1,000,000 Postchange loss (500,000) Taxable income--change year $ 500,000 Ratable Closing of allocation the books Prechange $ 250,000 $ 500,000 Postchange 250,000 0 Taxable income before NOL 500,000 500,000 NOL (350,000)(*) (500,000) Taxable income after NOL 150,000 0 NOL carryforward to 1996 (subject to Sec.

Closing of the books election pursuant to regs. sec. 1.382-6

24) Instead, they simply stated that the transferor shareholders had dividend income to the extent of their ratable share of undistributed E&P.

The correct E&P for measuring Sec. 356(a)(2) dividend income

Payment method with the recurring item exception: This method applies to taxpayers who have not elected the ratable accrual method but who have elected the recurring item exception.