New York Football Giants, Inc. - Page 7




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          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.]                                                      




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