- -9
Section 167(e)(5)(A) refers to section 1001(e)(2)6 for the
definition of "term interest in property", and section
167(e)(5)(B) refers to section 267(b)7 for the definition of a
"related person".
6 Sec. 1001(e)(2) provides:
Term interest in property defined.--For purposes of
paragraph (1), the term "term interest in property" means--
(A) a life interest in property,
(B) an interest in property for a term of years,
or
(C) an income interest in a trust.
7 Sec. 267 provides in part--
(b) Relationships.--The persons referred to in
subsection (a) are:
(1) Members of a family, as defined in subse
ction
(c)(4
);
* * * * * * *
(6) A fiduciary of a trust and a beneficiary
of such trust;
* * * * * * *
(c) Constructive Ownership of Stock.--
* * * * * *
(4) The family of an individual shall include
only his brothers and sisters (whether by the
whole or half blood), spouse, ancestors, and
lineal descendants * * *
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Last modified: May 25, 2011