§11801

al to 10 percent of the basis of energy property placed in service during the taxable year. Individuals are not entitled to a residential energy credit after November 4, 1990. Omnibus Budget - 7 - Reconciliation Act of 1990 (OBRA), Pub. L. 101-508, sec. 11801(a)(1), 104 Stat. 1388-520. Trusts are eligible for the energy tax credit after November 4, 1990, if they place qualifying energy property in service during the tax year. Sec. 38. Before enactment of OBRA, section 48(f) required trusts to ap

* * * The referenced definition of consolidated adjusted net book income provides that the term means consolidated net book income after taking into account certain enumerated adjustments.

ng expenditures in computing their liability under the now defunct wartime excise profits taxes had to follow a consistent practice for subsequent expenditures. Sec. 263(b) (repealed by the Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508, sec. 11801(a)(16), 104 Stat. 1388-520); sec. 1.162-14, Income Tax Regs. - 39 - 31 T.C. 1217, 1235 (1959) (“The amounts paid in 1951 and 1952 to produce * * * [a sales catalog] were capital items contributing to earning income for several years in the

he technical meaning advanced by petitioners. Moreover, section 448 does not define the word in that manner. In support of their contention petitioners cite section 585(b)(2),11 which describes "the experience method" that 11 Sec. 585, as amended by sec. 11801(c)(12) of the Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508, 104 Stat. 1388-527, provides in pertinent part as follows: SEC. 585. RESERVES FOR LOSSES ON LOANS OF BANKS. (a) Reserve for Bad Debts.-- (1) In general.--Except as p

he technical meaning advanced by petitioners. Moreover, section 448 does not define the word in that manner. In support of their contention petitioners cite section 585(b)(2),11 which describes "the experience method" that 11 Sec. 585, as amended by sec. 11801(c)(12) of the Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508, 104 Stat. 1388-527, provides in pertinent part as follows: SEC. 585. RESERVES FOR LOSSES ON LOANS OF BANKS. (a) Reserve for Bad Debts.-- (1) In general.--Except as p

he technical meaning advanced by petitioners. Moreover, section 448 does not define the word in that manner. In support of their contention petitioners cite section 585(b)(2),11 which describes "the experience method" that 11 Sec. 585, as amended by sec. 11801(c)(12) of the Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508, 104 Stat. 1388-527, provides in pertinent part as follows: SEC. 585. RESERVES FOR LOSSES ON LOANS OF BANKS. (a) Reserve for Bad Debts.-- (1) In general.--Except as p