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Code of Federal Regulations (Last Updated: July 5, 2024) |
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Title 26 - Internal Revenue |
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Chapter I - Internal Revenue Service, Department of the Treasury |
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SubChapter F - Procedure and Administration |
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Part 301 - Procedure and Administration |
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SubPart - Assessment |
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In General |
§ 301.6241-4 - Payments nondeductible.
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§ 301.6241-4 Payments nondeductible.
(a) Payments nondeductible. No deduction is allowed under subtitle A of the Internal Revenue Code (Code) for any payment required to be made by a partnership under subchapter C of chapter 63 of the Code (subchapter C of chapter 63). Payment by a partnership of any amount required to be paid under subchapter C of chapter 63, including any imputed underpayment (as defined in § 301.6241-1(a)(3)), or interest, penalties, additions to tax, or additional amounts with respect to an imputed underpayment, is treated as an expenditure described in section 705(a)(2)(B).
(b) Applicability date -
(1) In general. Except as provided in paragraph (b)(2) of this section, this section applies to partnership taxable years beginning after December 31, 2017, and ending after August 12, 2018.
(2) Election under § 301.9100-22 in effect. This section applies to any partnership taxable year beginning after November 2, 2015, and before January 1, 2018, for which a valid election under § 301.9100-22 is in effect.
[T.D. 9844, 84 FR 6571, Feb. 27, 2019]