§271 — Debts owed by political parties, etc.
65 cases·11 followed·3 distinguished·51 cited—17% support
Statute Text — 26 U.S.C. §271
In the case of a taxpayer (other than a bank as defined in section 581) no deduction shall be allowed under section 166 (relating to bad debts) or under section 165(g) (relating to worthlessness of securities) by reason of the worthlessness of any debt owed by a political party.
For purposes of subsection (a), the term “political party” means—
a political party;
a national, State, or local committee of a political party; or
a committee, association, or organization which accepts contributions or makes expenditures for the purpose of influencing or attempting to influence the election of presidential or vice-presidential electors or of any individual whose name is presented for election to any Federal, State, or local elective public office, whether or not such individual is elected.
For purposes of paragraph (1)(C), the term “contributions” includes a gift, subscription, loan, advance, or deposit, of money, or anything of value, and includes a contract, promise, or agreement to make a contribution, whether or not legally enforceable.
For purposes of paragraph (1)(C), the term “expenditures” includes a payment, distribution, loan, advance, deposit, or gift, of money, or anything of value, and includes a contract, promise, or agreement to make an expenditure, whether or not legally enforceable.
In the case of a taxpayer who uses an accrual method of accounting, subsection (a) shall not apply to a debt which accrued as a receivable on a bona fide sale of goods or services in the ordinary course of the taxpayer’s trade or business if—
for the taxable year in which such receivable accrued, more than 30 percent of all receivables which accrued in the ordinary course of the trades and businesses of the taxpayer were due from political parties, and
the taxpayer made substantial continuing efforts to collect on the debt.
Treasury Regulations
- Treas. Reg. §Treas. Reg. §1.271-1 Debts owed by political parties
- Treas. Reg. §Treas. Reg. §1.271-1(a) General rule.
- Treas. Reg. §Treas. Reg. §1.271-1(b) Definitions—(1) Political party.
65 Citing Cases
Conclusion We hold that the disputed legal expenses that Mylan incurred during the years at issue to prepare paragraph IV notice letters must be capitalized pursuant to section 263(a), whereas expenses incurred to litigate Section 271(e)(2) suits are - 48 - currently deductible pursuant to section 162(a).
Therefore, we hold that petitioners are liable under section 6901 as transferees ofa transferee.
Therefore, we hold that petitioners are liable under section 6901 as transferees ofa transferee.
However, because we hold that the D ebold Foundation is not liable as a transferee ofthe assets ofDouble-D Ranch, p titioners cannot be liable as transferees ofa transferee.
271B.13-010(6) (West 2020). - 18 - Furthermore, petitioner did not otherwise possess an ownership interest in Waterfront equivalent to that ofa shareholder. Because he was president and a director ofWaterfront, the Act, along with Waterfront's articles ofincorporation, expressly prohibited any part ofWaterfront's income or profit from being d
The basic definition of a "deficiency" in section 271 of the 1939 Code, like today's definition in section 6211(a), was "tax imposed" minus "amount shown as the tax"; but in the 1939 Code the "amount shown" "was "decreased by the amounts previously abated, credited; refunded, or otherwise repaid in respect of such tax" (emphasis added); and the deficiency was therefore increased by those a
The basic definition of a “deficiency” in section 271 of the 1939 Code, like today’s definition in section 6211(a), was “tax imposed” minus “amount shown as the tax”; but in the 1939 Code the “amount shown” was “decreased by the amounts previously abated, credited, refunded, or otherwise repaid in respect of such tax” (emphasis added); and the deficiency was therefore increased by those am
Petitioner contends that the language of the above-quoted regulation represents an impermissible extension of the current statute, reflecting instead section 271 of the Internal Revenue Code of 1939 .
271 (2001) and argues that the donees could have been compelled to surrender their NMG warrants. That section provides: SEC. 271. Sale, lease or exchange of assets; consideration; procedure. (a) Every corporation may at any meeting of its board of directors or governing body sell, lease or exchange all or substantially all of its property and
271 (2001) and argues that the donees could have been compelled to surrender their NMG warrants. That section provides: SEC. 271. Sale, lease or exchange of assets; consideration; procedure. (a) Every corporation may at any meeting of its board of directors or governing body sell, lease or exchange all or substantially all of its property and
Although there is no dispute that reasonable postreturn expenses are allowable for purposes of determining the ultimate estate tax, section 6663(a) specifically provides that the fraud penalty be imposed on "any part of any underpayment of tax required to be shown on a return".
The term “deficiency” was defined in section 271 of the 1939 Code much as it is defined both in the 1954 Code and today, and much as the term “underpayment” is defined in section 6664(a).
271.703(d)(11) (1988). The Wattenberg "J" field is located north and east of Denver and underlies approximately 703,000 acres situated within four different counties. See 18 C.F.R. sec. 271.703(d)(11)(i). Accordingly, it is a relatively large area within which many wells may be situated. The parties do not dispute and the case law supports the