Juan El Khouri and Kitty Hunter - Page 9




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               Section 7508(a)(1)(C) and (K) lists “Filing a petition with            
          the Tax Court for redetermination of a deficiency” and “Any other           
          act required or permitted under the internal revenue laws                   
          specified in regulations prescribed under this section by the               
          Secretary”, respectively, as acts with regard to which the                  
          Secretary may postpone the time for performance.6  Regarding acts           
          contemplated by section 7508(a)(1)(K), section 301.7508-1(a),               
          Proced. & Admin. Regs., provides that the period of time that may           
          be disregarded applies to acts specified in a revenue ruling,               
          revenue procedure, notice, or other guidance published in the               
          Internal Revenue Bulletin.                                                  
               Section 301.7508A-1(c)(1), Proced. & Admin. Regs., lists the           
          acts performed by “affected taxpayers” the time for the                     
          performance of which may be postponed.  Included within this list           
          of acts are “Filing a petition with the Tax Court” and “Any other           
          act specified in a revenue ruling, revenue procedure, notice,               
          announcement, news release, or other guidance published in the              
          Internal Revenue Bulletin”.  Sec. 301.7508A-1(c)(1)(iv), (vii),             
          Proced. & Admin. Regs.                                                      


               5(...continued)                                                        
          occurring on or after Jan. 23, 2002.  Id. sec. 112(f), 115 Stat.            
          2435.                                                                       
               6  Section 7508(a)(1)(K) was amended by the Victims of                 
          Terrorism Tax Relief Act of 2001, Pub. L. 107-134, sec. 112(b),             
          115 Stat. 2427, 2434, by striking the phrase “in regulations                
          prescribed under this section”.  The amendment applies as                   
          described supra note 5.                                                     





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