- 6 - (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 notPage: Previous 1 2 3 4 5 6 7 8 9 Next
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