- 24 - regulations, effective generally for taxable years beginning after December 31, 1986, were promulgated in 1993 pursuant to the Commissioner's authority found in section 7805(a) to "prescribe all needful rules and regulations for the enforcement of this title". T.D. 8514, 1994-1 C.B. 141; sec. 1.448-1(i)(1), Income Tax Regs.11 The final regulations interpreting section 10 (...continued) * * * * * * * (iii) Cessation of trade or business. If the taxpayer ceases to engage in the trade or business to which the section 481(a) adjustment relates, or if the taxpayer operating the trade or business terminates existence, and such cessation or termination occurs prior to the expiration of the adjustment period described in paragraph (g)(2)(i) or (ii) of this section, the taxpayer must take into account, in the taxable year of such cessation or termination, the balance of the adjustment not previously taken into account in computing taxable income. For purposes of this paragraph (g)(3)(iii), the determination as to whether a taxpayer has ceased to engage in the trade or business to which the section 481(a) adjustment relates, or has terminated its existence, is to be made under the principles of �1.446- 1(e)(3)(ii) and its underlying administrative procedures. 11 Sec. 1.448-1(i), Income Tax Regs., provides in pertinent part as follows: (i) Effective date. (1) In general. Except as provided in paragraph (i)(2), (3), and (4) of this section, this section applies to any taxable year beginning after December 31, 1986. * * * * * * * (4) Transitional rule for paragraphs (g) and (h) of this section. To the extent the provisions of paragraphs (g) and (h) of this section were not reflected in paragraphs (g) and (h) of �1.448-1T (as (continued...)Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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