- 10 - 1.469-2T(f)(6), Temporary Income Tax Regs., 53 Fed. Reg. 5686, 5723 (Feb. 25, 1988), served as the text of the proposed regulations). The notice of proposed rulemaking complied with the notice and comment requirements of the APA, supra; inter alia, it set forth by cross-reference the substance of the proposed regulations, including the subjects, issues, and rules involved, and it invited written comments. 53 Fed. Reg. 5733. The notice of proposed rulemaking also invited requests for a public hearing and stated that a public hearing would be held, upon the request of any commentator, at a time and place to be published in the Federal Register. Id. Section 1.469-4(a), Income Tax Regs., was prescribed by the Commissioner under the broad regulatory authority that Congress delegated to him through sections 469(l) and 7805, T.D. 8565, 1994-2 C.B. 81, 83, and is generally effective for taxable years ending after May 10, 1992, sec. 1.469-11(a)(1), Income Tax Regs. Section 1.469-4(a), Income Tax Regs., provides: � 1.469-4. Definition of activity.--(a) Scope and purpose. This section sets forth the rules for grouping a taxpayer's trade or business activities and rental activities for purposes of applying the passive activity loss and credit limitation rules of section 469. A taxpayer's activities include those conducted through C corporations that are subject to section 469 * * *. [Sec. 1.469-1T(b)(4), Temporary Income Tax Regs., 53 Fed. Reg. 5686, 5701 (Feb. 25, 1988), provides that a C corporation is subject to section 469 if it is a personal service corporation.] The second sentence of section 1.469-4(a), Income Tax Regs., which contains the attribution rule in dispute, is a change fromPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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