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(1) The rules contained in
� � 1.469-1, 1.469-1T, 1.469-2,
1.469-2T, 1.469-3, 1.469-3T,
1.469-4, 1.469-5, and 1.469-5T
apply for taxable years ending
after May 10, 1992.
* * * * * * *
(b) Additional effective dates--(1)
Application of 1992 amendments for taxable
years beginning before October 4, 1994. * *
* for taxable years that end after May 10,
1992, and begin before October 4, 1994, a
taxpayer may determine tax liability in
accordance with Project PS-1-89 published at
1992-1 C.B. 1219 * * *.
Project PS-1-89, supra, generally contains: (1) The second set
of regulations that the Commissioner issued to define the word
"activity", see Schwalbach v. Commissioner, supra at 220-225, for
a detailed discussion of the three sets of regulations which the
Commissioner issued on that subject, and (2) the effective date
rule in section 1.469-11(a)(1), Income Tax Regs.
Petitioners rely on the fact that the second set of
regulations made no mention of attributing the activity of a
corporation to a shareholder, see 57 Fed. Reg. 20802 (May 15,
1992), and that the first set of regulations provided that "a
taxpayer's activities do not include operations that a taxpayer
conducts through one or more entities (other than passthrough
entities)", see sec. 1.469-4T(b)(2)(ii)(B), Temporary Income Tax
Regs., 54 Fed. Reg. 20543 (May 12, 1989). According to
petitioners, the fact that the second set of regulations did not
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