Internal Revenue Bulletins  

April 25, 1994

Internal Revenue Bulletin No. 1994-17

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INCOME TAX

Rev. Rul. 94-25
LIF0; price indexes; department stores. The January 1994 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, January 31, 1994.

T.D. 853l
Final regulations under section 382 of the Code relate to the treatment of options in determining whether a loss corporation has an ownership change.

T.D. 8532
Final regulations under section 108 of the Code relate to discharge of indebtedness.

T.D. 8533
IA-78-93

Temporary and proposed regulations under section 6662 of the Code relate to the accuracy-related penalty. A public hearing will be held on July 12, 1994.

Notice 94-38
The Ninth Circuit has granted a rehearing in Albertson's Inc. v. Commissioner, in which it held that amounts accrued on nonqualified deferred compensation arrangements were currently deductible. The Service will not accept claims for refund to deduct such amounts and has temporarily suspended acceptance of applications for change in accounting method for deducting such amounts.

Notice 94-39
This notice alerts withholding agents and taxpayers that contingent interest described in section 871(h)(4) of the Code no longer qualifies for the portfolio debt exemption from withholding.

Notice 94-40
This notice summarizes the Service's experience with issuing advance pricing agreements to taxpayers with functionally fully integrated global trading operations.

Announcement 94-56
A list of organizations is provided that no longer qualify as organizations, contributions to which are deductible under section 170 of the Code.


EXCISE TAXES

Notice 94-44
A determination has been made to add benzoic acid and benzaldehyde to the list of taxable substances in section 4672(a)(3) of the Code.

Notice 94-45
A determination has been made to add diphenylamine and aniline to the list of taxable substances in section 4672(a)(3) of the Code.

Announcement 94-57
A petition to add dimethyl terephthalate to the list of taxable substances in section 4672(a)(3) of the Code has been filed.

Announcement 94-58
Petitions to add monochlorobenzene and ethyl chloride to the list of taxable substances in section 4672(a)(3) of the Code have been filed.

Announcement 94-59
Petitions to add tetrahydrofuran and 1,4 butanediol to the list of taxable substances in section 4672(a)(3) of the Code have been filed.


ADMINISTRATIVE

Rev. Proc. 94-31
Waiver of section 911 time requirements. This procedure provides a current list of countries to which section 911(d)(4) of the Code applies. Rev. Procs. 81-23 and 86-39 obsoleted.

Notice 94-42
This notice publishes the inflation adjustment factor, nonconventional source fuel credit, and the reference price for calendar year 1993 that determines the availability of the credit for producing fuel from a nonconventional source under section 29 of the Code.


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