- 7 - which it was an S corporation. Sec. 1374(d)(3). D. Petitioner’s Contentions Section 6245 provides that “the term ‘subchapter S item’ means any item of an S corporation to the extent regulations prescribed by the Secretary provide that * * * such item is more appropriately determined at the corporate level than at the shareholder level.” Section 301.6245-1T(a)(1)(vi)(G), Temporary Proced. & Admin. Regs., 52 Fed. Reg. 3003 (Jan. 30, 1987),4 defines subchapter S items to include taxes that are imposed at 4 Sec. 301.6245-1T, Temporary Proced. & Admin. Regs., 52 Fed. Reg. 3003 (Jan. 30, 1987), defines subchapter S items, in part, as follows: Sec. 301.6245-1T subchapter S items. (a) In general. For purposes of subtitle F of the Internal Revenue Code of 1986, the following items which are required to be taken into account for the taxable year of an S corporation under subtitle A of the Code are more appropriately determined at the corporate level than at the shareholder level and, therefore, are subchapter S items: (1) The S corporation aggregate and each shareholder’s share of, and any factor necessary to determine, each of the following: * * * * * * * (vi) Other amounts determinable at the corporate level with respect to corporate assets, investments, transactions, and operations necessary to enable the S corporation or the shareholders to determine-- * * * * * * * (G) The taxes imposed at the corporate level, such as the taxes imposed under secs. 56, 1374, or 1375; *** [Emphasis added.]Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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