- 36 - Provision re shareholder’s participation in his C corporation’s activities “Material “Activity” participation” Overall Year/event regulation regulation effect 1988 temporary Silent Parenthetical Shareholder regulations (no activity expressly does not (T.D. 8175) regulation) provides participate in shareholder C corporation does not activities participate in C corporation activities 1989 temporary Definition and Silent Shareholder regulations example (parenthetical does not (T.D. 8253) expressly removed) participate in provide C corporation shareholder activities does not participate in C corporation activities 1992 proposed Silent Silent ??? regulations (no definition (same as (at issue in (PS-1-89) or example) above) the case at hand) 1994 final Expressly Silent Shareholder regulations provides that (same as participates (T.D. 8565) taxpayer’s above) in activities activities of C include those corporations conducted subject to through C sec. 469 corporations subject to sec. 469 V. The 1992 Proposed Regulations Control This Case As the above discussion makes clear, the 1988 and 1989 temporary regulations expressly provided that shareholders didPage: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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