§ 1.269-7. Relationship of section 269 to sections 382 and 383 after the Tax Reform Act of 1986.
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/us/cfr/t26/s§ 1.269-7·A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
Section 269 and §§ 1.269-1 through 1.269-5 may be applied to disallow a deduction, credit, or other allowance notwithstanding that the utilization or amount of a deduction, credit, or other allowance is limited or reduced under section 382 or 383 and the regulations thereunder. However, the fact that the amount of taxable income or tax that may be offset by a deduction, credit, or other allowance is limited under section 382(a) or 383 and the regulations thereunder is relevant to the determination of whether the principal purpose of an acquisition is the evasion or avoidance of Federal income tax. [T.D. 8388, 57 FR 346, Jan. 6, 1992]
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§ 1.269-7
Relationship of section 269 to sections 382 and 383 after the Tax Reform Act of 1986.
Treas. Dec.T.D. 8388
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