§1146

1146 provides an exemption from Federal income taxes with respect to certain payments made pursuant to 25 U.S.C. subchapter LVI, we treat petitioners as having invoked the exemption of 25 U.S.C. sec. 1146. Petitioners contend, and stipulated exhibits in the record corroborate their contention, that the land on which the casino was located was

ency determined by the Tax Court." 'The legislative history of sec. 7486 (originally enacted as sec. 1001(d) by the Internal Revenue Act of 1926, ch. 27, 44 Stat. 110, amended by the Internal Revenue Aht of 1928, ch. 852, 45 Stat. 873, designated as sec. 1146 in the'Internal Revenue Code of 1939, and becoming sec. 7486 under the Internal Revenue Code of 1954) lacks any indication of congrepsional intent on the issue involved. See H. Rept. 1, 69th Cong.,, 1st Sess. (1925), 1939-1 C.B. (Part 2) 31

ency determined by the Tax Court.” 7The legislative history of sec. 7486 (originally enacted as sec. 1001(d) by the Internal Revenue Act of 1926, ch. 27, 44 Stat. 110, amended by the Internal Revenue Act of 1928, ch. 852, 45 Stat. 873, designated as sec. 1146 in the Internal Revenue Code of 1939, and becoming sec. 7486 under the Internal Revenue Code of 1954) lacks any indication of congressional intent on the issue involved. See H. Rept. 1, 69th Cong., 1st Sess. (1925), 1939-1 C.B. (Part 2) 315

on activity is currently taking place. The legislative history of sec. 7486 (originally enacted as sec. 1001(d) by the Internal Revenue Act of 1926, ch. 27, 44 Stat. 110, amended by the Internal Revenue Act of 1928, ch. 852, 45 Stat. 873, designated sec. 1146 in the Internal Revenue Code of 1939, and becoming sec. 7486 under the Internal Revenue Code of 1954) lacks any indication of congressional intent on the issue involved. See H. Rept. 1, 69th Cong., 1st Sess. (1925), 1939-1 C.B. (Part 2) 315

Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986, Pub. L. 99- 514, sec. 1146, 100 Stat. 2491, Congress amended sec. 414(n) to expand further the qualified plan restrictions on the use of leased employees. 30By a parity of reasoning, the organization and use of Intercoastal and MIT Personnel in efforts to maximize qua

Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986, Pub. L. 99- 514, sec. 1146, 100 Stat. 2491, Congress amended sec. 414(n) to expand further the qualified plan restrictions on the use of leased employees. 30By a parity of reasoning, the organization and use of Intercoastal and MIT Personnel in efforts to maximize qua

Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986, Pub. L. 99- 514, sec. 1146, 100 Stat. 2491, Congress amended sec. 414(n) to expand further the qualified plan restrictions on the use of leased employees. 30By a parity of reasoning, the organization and use of Intercoastal and MIT Personnel in efforts to maximize qua

Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986, Pub. L. 99- 514, sec. 1146, 100 Stat. 2491, Congress amended sec. 414(n) to expand further the qualified plan restrictions on the use of leased employees. 30By a parity of reasoning, the organization and use of Intercoastal and MIT Personnel in efforts to maximize qua

Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986, Pub. L. 99- 514, sec. 1146, 100 Stat. 2491, Congress amended sec. 414(n) to expand further the qualified plan restrictions on the use of leased employees. 30By a parity of reasoning, the organization and use of Intercoastal and MIT Personnel in efforts to maximize qua

Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986, Pub. L. 99- 514, sec. 1146, 100 Stat. 2491, Congress amended sec. 414(n) to expand further the qualified plan restrictions on the use of leased employees. 30By a parity of reasoning, the organization and use of Intercoastal and MIT Personnel in efforts to maximize qua

Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986, Pub. L. 99- 514, sec. 1146, 100 Stat. 2491, Congress amended sec. 414(n) to expand further the qualified plan restrictions on the use of leased employees. 30By a parity of reasoning, the organization and use of Intercoastal and MIT Personnel in efforts to maximize qua

Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986, Pub. L. 99- 514, sec. 1146, 100 Stat. 2491, Congress amended sec. 414(n) to expand further the qualified plan restrictions on the use of leased employees. 30By a parity of reasoning, the organization and use of Intercoastal and MIT Personnel in efforts to maximize qua

Stat. 875, granting authority to the Secretary to issue regulations deemed necessary to prevent employee leasing or other arrangements from being used to avoid statutory employee benefit requirements. In the Tax Reform Act of 1986, Pub. L. 99- 514, sec. 1146, 100 Stat. 2491, Congress amended sec. 414(n) to expand further the qualified plan restrictions on the use of leased employees. 30By a parity of reasoning, the organization and use of Intercoastal and MIT Personnel in efforts to maximize qua