99-16163. Regulations Under Section 382 of the Internal Revenue Code of 1986; Application of Section 382 in Short Taxable Years and With Respect to Controlled Groups  

  • [Federal Register Volume 64, Number 127 (Friday, July 2, 1999)]
    [Rules and Regulations]
    [Pages 36175-36181]
    From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
    [FR Doc No: 99-16163]
    
    
    -----------------------------------------------------------------------
    
    DEPARTMENT OF THE TREASURY
    
    Internal Revenue Service
    
    26 CFR Parts 1 and 602
    
    [TD 8825]
    RIN 1545-AU33
    
    
    Regulations Under Section 382 of the Internal Revenue Code of 
    1986; Application of Section 382 in Short Taxable Years and With 
    Respect to Controlled Groups
    
    AGENCY: Internal Revenue Service (IRS), Treasury.
    
    ACTION: Final and temporary regulations.
    
    -----------------------------------------------------------------------
    
    SUMMARY: This document contains final regulations relating to 
    limitations on net operating loss carryovers and certain built-in 
    losses following an ownership change of a corporation. The regulations 
    implement the statutory authority under section 382(m) of the Internal 
    Revenue Code to prescribe regulations concerning short taxable years 
    and controlled groups of corporations. Additional rules are adopted 
    relating principally to corporations that cease to exist following a 
    merger (or similar transaction) or that have two or more ownership 
    changes. These final regulations replace temporary regulations that 
    provided guidance on these topics.
    
    DATES: Effective Dates: These regulations are effective June 25, 1999.
        Applicability Dates: For dates of application and special 
    transition rules, see Effective Dates under SUPPLEMENTARY INFORMATION.
    
    FOR FURTHER INFORMATION CONTACT: Lee A. Kelley at 202-622-7550 (not a 
    toll-free number).
    
    SUPPLEMENTARY INFORMATION:
    
    Paperwork Reduction Act
    
        The collection of information contained in these final regulations 
    has been reviewed and approved by the Office of Management and Budget 
    in accordance with the Paperwork Reduction Act (44 U.S.C. 3507) under 
    control number 1545-1434. Responses to this collection of information 
    are required to obtain a benefit relating to the value of a controlled 
    group member.
        An agency may not conduct or sponsor, and a person is not required 
    to respond to, a collection of information unless the collection of 
    information displays a valid control number.
        The estimated annual burden per respondent is one quarter hour.
        Comments concerning the accuracy of this burden estimate and 
    suggestions for
    
    [[Page 36176]]
    
    reducing this burden should be sent to the Internal Revenue Service, 
    Attn: IRS Reports Clearance Officer, OP:FS:FP, Washington, DC 20224, 
    and to the Office of Management and Budget, Attn: Desk Officer for the 
    Department of the Treasury, Office of Information and Regulatory 
    Affairs, Washington, DC, 20503.
        Books and records relating to this collection of information must 
    be retained as long as their contents may become material in the 
    administration of any internal revenue law. Generally, tax returns and 
    tax return information are confidential, as required by 26 U.S.C. 6103.
    
    Background and Explanation of Provisions
    
        On February 4, 1991, the IRS and Treasury issued a notice of 
    proposed rulemaking, CO-077-90 (56 FR 4183) (the 1991 controlled group 
    proposed regulations), setting forth rules regarding the application of 
    section 382 to controlled groups of corporations and to corporations 
    that undergo a merger or similar transaction. The 1991 controlled group 
    proposed regulations also related to the determination of the section 
    382 limitation following an ownership change in the case of short 
    taxable year, and to the valuation of the stock of a loss corporation 
    for purposes of determining the amount of the section 382 limitation. 
    On the same day, the IRS and Treasury also issued proposed regulations 
    relating to the application of section 382 to affiliated groups of 
    corporations filing consolidated returns (CO-132-87, 56 FR 4194), and 
    to the use of built-in deductions and net operating losses and capital 
    losses, including the carryover and carryback of separate return year 
    (SRLY) losses, of members of consolidated groups (CO-078-90, 56 FR 
    4228). A public hearing regarding the three sets of proposed 
    regulations was held on April 8, 1991.
        On June 27, 1996, the IRS and Treasury published temporary 
    regulations (TD 8679, 61 FR 33313) (the 1996 controlled group temporary 
    regulations) relating to section 382. Except for the addition of a 
    provision relating to the effects of successive ownership changes, 
    these regulations were substantially identical to the 1991 controlled 
    group proposed regulations. A notice of proposed rulemaking cross-
    referencing the temporary regulations was published in the Federal 
    Register on the same day (CO-026-96, 61 FR 33391) (the 1996 controlled 
    group proposed regulations) and the 1991 controlled group proposed 
    regulations were withdrawn. No written comments were received on the 
    1996 controlled group proposed regulations and no public hearing was 
    held. Also on June 27, 1996, the IRS and Treasury published temporary 
    regulations relating to the application of section 382 to affiliated 
    groups of corporations filing consolidated returns (TD 8678, 61 FR 
    33335) and the SRLY limitation (TD 8677, 61 FR 33321). Notices of 
    proposed rulemaking cross-referencing these temporary regulations were 
    published on the same day (CO-025-96, 61 FR 33395 and CO-024-96, 61 FR 
    33393), and the corresponding proposed regulations published in 1991 
    were withdrawn.
        The 1996 controlled group proposed regulations are adopted as 
    revised by this Treasury decision and the corresponding temporary 
    regulations are removed. The final regulations are substantially the 
    same as the 1996 controlled group proposed regulations, with one 
    significant change relating to built-in losses of a member of a 
    controlled group of corporations. This change is discussed below.
        Under section 382, if an ownership change occurs with respect to a 
    loss corporation (as defined in section 382 and the regulations 
    thereunder), the amount of the loss corporation's taxable income for a 
    post-change year that may be offset by the net operating loss 
    carryovers arising before the ownership change are subject to a 
    limitation known as the section 382 limitation. The section 382 
    limitation for a post-change taxable year of the loss corporation 
    generally equals the fair market value of the stock of the corporation 
    immediately before the ownership change multiplied by the long-term tax 
    exempt rate (a rate of return published periodically in the Internal 
    Revenue Bulletin).
        In addition to net operating loss carryovers, the recognized built-
    in losses of corporations that have a net unrealized built-in loss on 
    the ownership change date are also subject to the section 382 
    limitation. In general, a corporation has a net unrealized built-in 
    loss on its ownership change date if the adjusted basis of its assets 
    exceeds their fair market value, and such excess is greater than the 
    threshold amount under section 382(h)(3)(B). In general, recognized 
    built-in losses are losses with respect to assets held on the change 
    date that are recognized within the 5-year period beginning on the 
    ownership change date. The recognized built-in loss on an asset, 
    however, is limited to the lesser of the loss recognized on its 
    disposition or the amount by which the adjusted basis of the asset 
    exceeded its fair market value on the change date.
        Consistent with the proposed regulations, the final regulations 
    require appropriate adjustments to the value of a loss corporation that 
    is a member of a controlled group of corporations so that the same 
    value is not included more than once in computing the section 382 
    limitations for the loss corporations that are members of the 
    controlled group. In general, adjustments are required only when 
    corporations are members of the same controlled group both when a pre-
    change loss arises and on the date of the ownership change. Thus, 
    adjustments are required if a loss corporation is a component member of 
    the same controlled group as another member (i) on December 31 of the 
    taxable year in which a pre-change loss arises (or the change date, if 
    earlier) and (ii) on the date that the loss corporation has an 
    ownership change. If a loss corporation has pre-change losses that 
    arise in different taxable years, the component members of the 
    controlled group with respect to losses arising in each taxable year 
    may differ. Therefore, as in the 1996 controlled group proposed 
    regulations, the final regulations are applied by determining a 
    controlled group with respect to each year's pre-change loss of the 
    corporation (a controlled group loss).
        To avoid duplication of value in connection with a controlled group 
    loss, the value of the stock of each corporation that is a component 
    member of the controlled group with respect to a controlled group loss 
    is reduced by the value of the stock of other component members that it 
    directly owns immediately before the ownership change. A second 
    adjustment (more fully explained in the preamble to the 1991 controlled 
    group proposed regulations) permits a lower tier member to elect to 
    restore some or all of the previously reduced value to a member that 
    directly owns its stock.
        In identifying controlled group losses, the determination of the 
    taxable year to which a net operating loss carryover is attributable 
    usually presents no difficulty. The determination of the taxable year 
    in which a net unrealized built-in loss accrues, however, is more 
    problematic. To address some concerns in this area, the final 
    regulations include an irrebutable presumption that certain built-in 
    losses are attributable to the period before a particular taxable year. 
    The presumption applies to a loss corporation that had an ownership 
    change prior to the first day of the taxable year in question, and 
    whose net unrealized built-in losses became subject to a section 382 
    limitation as a result of that ownership change. Under
    
    [[Page 36177]]
    
    the presumption, any built-in loss in such an asset is considered to be 
    attributable to a period prior to the taxable year in question to the 
    extent of the built-in loss in that asset on the previous change date.
    
    Effective Dates
    
        Section 1.382-5 (relating to the section 382 limitation) generally 
    applies to a loss corporation that has an ownership change to which 
    section 382(a), as amended by the Tax Reform Act of 1986, applies. The 
    rules in that section relating to successive ownership changes, 
    however, apply to taxable years of a loss corporation beginning on or 
    after January 1, 1997. Section 1.382-8 (relating to controlled groups 
    of corporations) generally applies to a loss corporation that has an 
    ownership change with respect to a controlled group loss on or after 
    January 1, 1997. Transition rules are provided for members of 
    controlled groups that have ownership changes before that date. The 
    rules in Sec. 1.382-1(a)(iv) (relating to separate tracking of certain 
    loss corporations) apply to testing dates on or after January 29, 1991. 
    The rules in Sec. 1.382-2 (a) (4) and (a) (5) relating to successor or 
    predecessor corporations in other than corporate reorganizations apply 
    to testing dates on or after January 1, 1997.
    
    Special Analysis
    
        It has been determined that this Treasury decision is not a 
    significant regulatory action as defined in EO 12866. It has also been 
    determined that section 553 of the Administrative Procedure Act (5 
    U.S.C. chapter 5) does not apply to these regulations. It is hereby 
    certified that these regulations do not have a significant economic 
    impact on a substantial number of small entities. This certification is 
    based on the fact that the collection of information in this regulation 
    is a statement of election that it is estimated will take less than one 
    hour to prepare. The statement will be filed by electing corporations 
    that are members of a controlled group of corporations (determined by 
    applying a 50% common control requirement) both (1) when a net 
    operating loss carryover (or certain other tax attributes ) arises and 
    (2) a member of the controlled group has an ownership change under 
    section 382 of the Internal Revenue Code with respect to that net 
    operating loss carryover (or other attribute). (An affiliated group of 
    corporations that files a consolidated return is treated as a single 
    corporation for this purpose, which reduces the number of potential 
    filers.) Because the election is only filed with respect to an 
    ownership change, it is unlikely that a corporation will file the 
    election frequently. Therefore, a Regulatory Flexibility Analysis under 
    the Regulatory Flexibility Act (5 U.S.C. chapter 6) is not required. 
    Pursuant to section 7805(f) of the Internal Revenue Code, the notice of 
    proposed rulemaking preceding these regulations was submitted to the 
    Small Business Administration for comment on its impact on small 
    business.
        Drafting information. The principal author of these regulations is 
    Lee A. Kelley of the Office of Assistant Chief Counsel (Corporate). 
    Other personnel from the IRS and Treasury participated in their 
    development.
    
    List of Subjects
    
    26 CFR Part 1
    
        Income taxes, Reporting and recordkeeping requirements.
    
    26 CFR Part 602
    
        Reporting and recordkeeping requirements.
    
    Adoption of Amendments to the Regulations
    
        Accordingly, 26 CFR parts 1 and 602 are amended as follows:
    
    PART 1--INCOME TAXES
    
        Paragraph 1. The authority citation for part 1 is amended by 
    removing entries for sections 1.382-5T and 1.382-8T and by adding 
    entries in numerical order to read in part as follows:
    
        Authority: 26 U.S.C. 7805 * * *
        Section 1.382-5 also issued under 26 U.S.C. 382(m). * * *
        Section 1.382-8 also issued under 26 U.S.C. 382(m). * * *
    
        Par. 2. Section 382-1 is amended by:
        1. Revising the entry for Sec. 1.382-2, paragraph (a)(1)(iv).
        2. Adding an entry for Sec. 1.382-2, paragraph (a)(1)(v).
        3. Adding entries for Sec. 1.382-2, paragraphs (a)(5) and (a)(6).
        4. Removing the entries for Sec. 1.382-2T, paragraphs (f)(1)(i), 
    (f)(1)(ii), and (f)(1)(iii).
        5. The entry for Sec. 1.382-4 is amended as follows:
        a. The entry for paragraph (b) is revised.
        b. Entries for paragraphs (b)(1) and (b)(2) are added.
        6. Removing the entry for Sec. 1.382-5.
        7. Redesignating the entry for Sec. 1.382-5T as Sec. 1.382-5 and 
    revising the section heading.
        8. Removing the entry for Sec. 1.382-8.
        9. Redesignating the entry for Sec. 1.382-8T as Sec. 1.382-8, 
    revising the section heading, and adding entries for paragraphs (b) (1) 
    and (b) (2).
        The revision and additions read as follows:
    
    
    Sec. 1.382-1  Table of contents.
    
    * * * * *
    
    Sec. 1.382-2  General rules for ownership change.
    
        (a) * * *
        (1) * * *
        (iv) End of separate accounting for losses and credits of 
    distributor or transferor corporation.
        (v) Application to other successor corporations.
    * * * * *
        (5) Successor corporation.
        (6) Predecessor corporation.
    * * * * *
    
    Sec. 1.382-4  Constructive ownership of stock.
    
    * * * * *
        (b) Attribution from corporations, partnerships, estates and 
    trusts.
        (1) [Reserved].
        (2) Limitation.
    * * * * *
    
    Sec. 1.382-5  Section 382 limitation.
    
    * * * * *
    
    Sec. 1.382-8  Controlled groups.
    
    * * * * *
        (b) * * *
        (1) In general.
        (2) Presumption regarding net unrealized built-in loss.
    * * * * *
    
    
    Sec. 1.1382-2  [Amended]
    
        Par. 2a. Section 1.382-2 is amended by removing paragraph 
    (a)(1)(iv).
        Par. 3. Section 1.382-2T is amended as follows:
        1. In paragraph (e)(2)(iv) Example (2)(ii), remove the reference 
    ``paragraph (f)(1)(ii)'' and add ``Sec. 1.382-2(a)(1)(iv)'' in its 
    place.
        2. Paragraph (f)(1)(ii) is redesignated as paragraph (a)(1)(iv) of 
    Sec. 1.382-2.
        3. Paragraph (f)(1) is revised.
        4. Paragraphs (f)(4) and (f)(5) are redesignated as paragraphs 
    (a)(5) and (a)(6) of Sec. 1.382-2, respectively.
        5. New paragraphs (f)(4) and (f)(5) are added.
        6. In paragraph (h)(2)(i)(A), remove the language ``and solely for 
    purposes of determining whether a loss corporation has an ownership 
    change''.
        The revision and additions read as follows:
    
    
    Sec. 1.382-2T  Definition of ownership change under section 382, as 
    amended by the Tax Reform Act of 1986 (temporary).
    
    * * * * *
        (f) Definitions. * * *
        (1) Loss corporation. See section 382 and Sec. 1.382-2(a)(1) for 
    the definition of a loss corporation.
    * * * * *
    
    [[Page 36178]]
    
        (4) Successor corporation. See Sec. 1.382-2(a)(5) for the 
    definition of successor corporation.
        (5) Predecessor corporation. See Sec. 1.382-2(a)(6) for the 
    definitions of predecessor corporation.
    * * * * *
        Par. 4. Section 1.382-2 is amended as follows:
        1. In the first sentence of paragraph (a)(1)(iii), remove the 
    reference ``Sec. 1.382-2T(f)(1)(ii)'' and add ``paragraph (a)(1)(iv) of 
    this section'' in its place.
        2. In the first sentence of newly designated paragraph (a)(1)(iv), 
    remove the reference ``Sec. 1.382-2(a)(1)(iii)'' and add `` paragraph 
    (a)(1)(iii) of this section'' in its place.
        3. In the first sentence of newly designated paragraph (a)(1)(iv), 
    remove the reference ``Sec. 1.382-2(a)(1)(ii)'' and add ``paragraph 
    (a)(1)(ii) of this section'' in its place.
        4. In the last sentence of newly designated paragraph (a)(1)(iv), 
    remove the reference ``paragraph (f)(1)(ii)'' and add ``paragraph 
    (a)(1)(iv)'' in its place.
        5. Paragraph (a)(1)(v) is added.
        6. In the first sentence of paragraph (a)(3)(i), remove the 
    reference ``paragraph (f)(18)'' and add ``paragraph (a)(3)(i) and 
    Sec. 1.382-2T(f)(18)(ii) and (iii)'' in its place.
        7. In the last sentence of newly designated paragraph (a)(5), 
    remove the reference ``paragraph (f)(4)'' and add ``paragraph (a)(5)'' 
    in its place.
        8. In the last sentence of newly designated paragraph (a)(6), 
    remove the reference ``paragraph (f)(5)'' and add ``paragraph (a)(6)'' 
    in its place.
        The addition reads as follows:
    
    
    Sec. 1.382-2  General rules for ownership change.
    
        (a) * * *
        (1) * * *
        (v) Application to other successor corporations. This paragraph 
    (a)(1) also applies, as the context may require, to successor 
    corporations other than successors in section 381(a) transactions. For 
    example, if a corporation receives assets from the loss corporation 
    that have basis in excess of value, the recipient corporation's basis 
    for the assets is determined, directly or indirectly, in whole or in 
    part, by reference to the loss corporation's basis, and the amount by 
    which basis exceeds value is material, the recipient corporation is a 
    successor corporation subject to this paragraph (a)(1). This paragraph 
    (a)(1)(v) applies to any testing date occurring on or after January 1, 
    1997.
    * * * * *
        Par. 5. Section 1.382-4 is amended by revising paragraph (b) to 
    read as follows:
    
    
    Sec. 1.382-4  Constructive ownership of stock.
    
    * * * * *
        (b) Attribution from corporations, partnerships, estates and 
    trusts. (1) [Reserved].
        (2) Limitation. Section 1.382-2T(h)(2)(i)(A) applies solely for 
    purposes of determining whether a loss corporation has an ownership 
    change.
    * * * * *
    
    
    Sec. 1.382-5  [Removed]
    
        Par. 6. Section 1.382-5 is removed.
        Par. 7. Section 1.382-5T is redesignated as Sec. 1.382-5 and 
    amended as follows:
        1. The section heading is revised.
        2. In paragraph (e), the reference ``Sec. 1.382-8T'' is removed and 
    ``Sec. 1.382-8'' is added in its place.
        The revision reads as follows:
    
    
    Sec. 1.382-5  Section 382 limitation.
    
    * * * * *
    
    
    Sec. 1.382-8  [Removed]
    
        Par. 8. Section 1.382-8 is removed.
        Par. 9. Section 1.382-8T is redesignated as Sec. 1.382-8 and 
    amended as follows:
        1. The section heading is revised.
        2. Redesignate paragraphs (b) introductory text, (b)(1) and (b)(2) 
    as paragraphs (b)(1) introductory text, (b)(1)(i) and (b)(1)(ii), 
    respectively.
        3. A paragraph heading for newly designated paragraph (b)(1) is 
    added.
        4. Paragraph (b)(2) is added.
        5. The first three sentences of paragraph (f) are revised.
        6. The graphics of paragraph (g) Example 1(a) are revised.
        7. The graphics of paragraph (g) Example 2(a) are revised.
        8. Paragraph (g) Example 4 is amended as follows:
        a. In the last sentence of paragraph (a), remove the reference 
    ``Sec. 1.1502-92T(b)(1)(i)'' and add ``Sec. 1.1502-92(b)(1(i)'' in its 
    place.
        b. In paragraph (b)(2), remove the reference ``Sec. 1.1502-91T(c)'' 
    and add ``Sec. 1.1502-91(c)'' in its place.
        c. In paragraph (c), remove the reference ``Sec. 1.1502-93T'' and 
    add ``Sec. 1.1502-93'' in its place.
        9. In the fifth sentence of paragraph (h)(1), remove the reference 
    ``Sec. 1.382-8T'' and add ``Sec. 1.382-8'' in its place.
        10. Paragraph (i) is added.
        The additions and revisions read as follows:
    
    
    Sec. 1.382-8  Controlled groups.
    
    * * * * *
        (b) Controlled group loss and controlled group with respect to a 
    controlled group loss--(1) In general. * * *
        (2) Presumption regarding net unrealized built-in loss. For 
    purposes of determining whether a net unrealized built-in loss of a 
    loss corporation is attributable to a taxable year (the determination 
    year) with respect to which the corporation is a component member of a 
    controlled group, the built-in loss in a prior change date asset is 
    deemed to be attributable to a period ending before the determination 
    year. A prior change date asset is any asset held by the loss 
    corporation at all times during the period beginning on the change date 
    of its most recent ownership change after 1986 (the first change date), 
    and ending on the first day of the determination year. The built-in 
    loss in a prior change date asset is the amount by which the adjusted 
    basis of the asset on the first change date exceeds the fair market 
    value of the asset on that date. The principles of this paragraph 
    (b)(2) also apply to items described in section 382(h)(6)(B).
    * * * * *
        (f) Coordination between consolidated groups and controlled groups. 
    Some or all of the component members of a controlled group may also be 
    members of a consolidated group, and a controlled group loss may be 
    subject to a consolidated section 382 limitation or subgroup section 
    382 limitation determined under Sec. 1.1502-93. Except as otherwise 
    provided in this paragraph (f) and Secs. 1.1502-91 through 1.1502-99, 
    Sec. 1.1502-93 applies instead of this section when both sections, by 
    their terms, are otherwise applicable. This section is applicable and 
    may require an adjustment to value if a member of a consolidated group, 
    a loss group, or loss subgroup (as those terms are defined in 
    Secs. 1.1502-1(h) and 1.1502-91) is also a component member of a 
    controlled group with respect to a controlled group loss. * * *
        (g) * * *
    
        Example 1. * * * (a) * * *
    
    BILLING CODE 4830-01-U
    
    [[Page 36179]]
    
    [GRAPHIC] [TIFF OMITTED] TR02JY99.019
    
    
    
    
    [[Page 36180]]
    
    
    * * * * *
        Example 2.  * * * (a) * * *
        [GRAPHIC] [TIFF OMITTED] TR02JY99.020
        
    
    BILLING CODE 4830-01-C
    
    [[Page 36181]]
    
    * * * * *
        (i) References to former temporary regulations. As the context 
    requires, a reference in this section to Sec. 1.382-8 includes a 
    reference to Sec. 1.382-8T in effect prior to June 25, 1999, as 
    contained in 26 CFR part 1 revised as of April 1, 1999, a reference to 
    Secs. 1.1502-91, 1.1502-92, 1.1502-93, and Secs. 1.1502-91 through 
    1.1502-99 includes a reference to Secs. 1.1502-91A, 1.1502-92A, 1.1502-
    93A and Secs. 1.1502-91A through 1.1502-99A.
    * * * * *
    
    PART 602--OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT
    
        Par. 10. The authority citation for part 602 continues to read as 
    follows:
    
        Authority: 26 U.S.C. 7805.
    
        Par. 11. In Sec. 602.101, paragraph (b) is amended in the table by 
    removing the entry for 1.382-8T and adding an entry in numerical order 
    to read as follows:
    
    
    Sec. 602.101  OMB Control numbers.
    
    * * * * *
        (b) * * *
    
    ------------------------------------------------------------------------
                                                                Current OMB
       CFR part or section where identified and described       control No.
    ------------------------------------------------------------------------
     
                      *        *        *        *        *
    1.382-8.................................................       1545-1434
     
                      *        *        *        *        *
    ------------------------------------------------------------------------
    
    John M. Dalrymple,
    Acting Deputy Commissioner of Internal Revenue.
        Approved: June 18, 1999.
    Donald C. Lubick,
    Assistant Secretary of the Treasury.
    [FR Doc. 99-16163 Filed 6-25-99; 1:27 pm]
    BILLING CODE 4830-01-U
    
    
    

Document Information

Published:
07/02/1999
Department:
Internal Revenue Service
Entry Type:
Rule
Action:
Final and temporary regulations.
Document Number:
99-16163
Pages:
36175-36181 (7 pages)
Docket Numbers:
TD 8825
RINs:
1545-AU33: Regulations Under Section 382
RIN Links:
https://www.federalregister.gov/regulations/1545-AU33/regulations-under-section-382
PDF File:
99-16163.pdf
CFR: (10)
26 CFR 1.382-2T(f)(18)(ii)
26 CFR 602.101
26 CFR 1.382-1
26 CFR 1.382-2
26 CFR 1.382-4
More ...