275, 283-84 (1967) (rejecting the contention that section 263 is dispositive on capitalization issues
and indicating that the principles of capitalization and clear reflection of income are "inextricably intertwined").
As much as we would all like to believe that this regulation will put an end to controversy in this area, our collective experiences in dealing with capitalization issues
suggests this may be overly optimistic.
. TEI referred to the recent advance notice of proposed rulemaking concerning capitalization issues
The most contentious capitalization issues
are those where revenue agents propose adjustments for intangible "significant future benefits" that have no readily ascertainable life and for which the current rules permit no amortization deduction.
Today, we are busy analyzing a new set of R&D credit rules that, while far from perfect, are more reasonable and grounded in reality, and we are studying a framework for comprehensive guidance on capitalization issues
that hold the promise of moderating the drain those issues have been on both IRS and taxpayer resources.
Therefore, a feasibility analysis should also consider certain ownership and capitalization issues
The Institute also commended the Treasury Department for the recent advanced notice of proposed rulemaking on capitalization issues
. TEI has consistently encouraged the issuance of bright-line rules that will quell the frequent disputes and needless controversies that have arisen since the INDOPCO decision, the organization stated.
The Notice acknowledges that the scope of controversies over capitalization issues
has increased in the wake of the decision in INDOPCO v.
He noted that the department is also working on ways providing bright-line guidance on capitalization issues
According to the document, the proposal attempts to "set forth an administrable and practical framework for addressing capitalization issues
by providing objective principles that draw lines between capital expenditures and deductible expenses."
Large capitalization issues
succumbed to selling, weighing on stock indexes, but small-cap shares were picked up.
Skillman, urging the government to follow through on the Priority Guidance Plan and issue much-needed guidance on capitalization issues
. The letter was prepared under the aegis of TEI's Federal Tax Committee, whose chair is Mitchell S.