...have been resolved in the Appeals Division of the IRS. [Staff of the Joint Committee on Taxation, 99th Cong., 1st Sess., General Explanation of the Tax Reform Act of 1986, p. 1300 (Jt. Comm. Print 1987).] It is clear that the parties could have settled this case in the audit...

...components for sale or use in carrying on the taxpayers trade or business. Joint Conm. on Taxation, 100th Cong., 1st Sess., General Explanation of the Tax Reform Act of 1986 (Comm. Print 1987). Under prior law, the credit was 25Z of qualified research expenses minus the average...

...have been resolved in the Appeals Division of the IRS. [Staff of the Joint Committee on Taxation, 99th Cong., 1st Sess., General Explanation of the Tax Reform Act of 1986, p. 1300 (Jt. Comm. Print 1987).] It is clear that the parties could have settled this case in the audit...

...for losses on bad debts under the bank experience method. Staff of the Joint Committee on Taxation, 100th Cong., 1st Sess., General Explanation of the Tax Reform Act of 1986 at 556 (Comm. Print 1987). * There is no contrary indication in the pre-enactment explanations of the...

...appropriate to impose current US taxation under subpart F. See staff of Joint Committee on Taxation, 100th Cong., 1st Sess. , General Explanation of the Tax Reform Act of 1986 ("Blue Book") , at 968. Thus, unless the US shareholder incurs the administrative burden and expense...

...appropriate to impose current US taxation under subpart F. See Staff of Joint Committee on Taxation, 100th Cong., 1st Sess., General Explanation of the Tax Reform Act of 1986 ("Blue Book"), at 968. Thus, unless the US shareholder incurs the administrative burden and expense...

...(contained in sec. 201 of this bill, described below). 3 See Staff of the Joint Committee on Taxation, 100th Cong., 1st Sess., General Explanation of the Tax Reform Act of 1986 at 1096 (1987); Treas. Reg. sec. 1.985-3. Effective Date The provision is effective for taxable years...

...Treasury, the cost of capital in Puerto Rico could be 1.0 to 1.5 percentage Id. Id. Section 936(d) (2) . * Staff of the Joint Comm. on Tax'n, 100th Cong., 1st...Tax Reform Act of 1986, at 1002 (Comm. Print 1987) . 1 Based on statistics for 1987 and 1988, the average GNP of the four Andean Countries was $16.65...

...income by virtue of the dealer exception in sec. 954(c)...." Staff of the Joint Committee on Taxation, 100th Cong., 1st Sess., General Explanation of the Tax Reform Act of 1986. at 1025(1987). 38 Under the Notice, for example, the IRS conditioned active asset treatment of securities...

...(contained in sec. 201 of this bill, described below). * See Staff of the Joint Committee on Taxation, 100th Cong., 1st Sess., General Explanation of the Tax Reform Act of 1986 at 1096 (1987); Treas. Reg. sec. 1.985-3. Effective Date The provision is effective for taxable years...