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IRB 2006-12

Table of Contents
(Dated March 20, 2006)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2006-12. Click on an entry to view the entry. Items shown under "Highlights of This Issue" open summaries of each IRB-referenced document only. Scroll to Parts I, II, etc. to view the full text versions of each IRB-referenced document. Use the "Keyword Search" option of TouchTax to search the full text of all Internal Revenue Bulletins, including this IRB.

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Highlights of This Issue

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

TEFRA partnership provisions; classification of items. This ruling provides that the tax treatment by an affiliated group on a consolidated return of the parent corporation’s payment to a partnership, in which the parent is not a partner, is not a “partnership item” within the meaning of section 6231(a)(3) of the Code or an “affected item” within the meaning of section 6231(a)(5), even if another member of the group is a partner in the partnership.

Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning April 1, 2006, will be 7 percent for overpayments (6 percent in the case of a corporation), 7 percent for underpayments, and 9 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 4.5 percent.

This notice informs Alabama, Louisiana, and Mississippi of their state population portion in the Gulf Opportunity Zone required to determine the (1) Gulf Opportunity housing amount under section 1400N(c)(1)(B) of the Code, and (2) maximum aggregate face amount of qualified Gulf Opportunity Zone Bonds under section 1400N(a)(3) of the Code.

This notice informs taxpayers of amendments that will be made to the final regulations (T.D. 9241, 2006-7 I.R.B. 427) under section 671 of the Code regarding certain reporting rules for non-mortgage widely held fixed investment trusts (NMWHFITs). Until such amendments reflecting these changes are issued, taxpayers may rely on this notice.

EXEMPT ORGANIZATIONS

John A. Hyman Memorial Youth Foundation of Warrenton, NC, no longer qualifies as an organization to which contributions are deductible under section 170 of the Code.

A list is provided of organizations now classified as private foundations.

ADMINISTRATIVE

TEFRA partnership provisions; classification of items. This ruling provides that the tax treatment by an affiliated group on a consolidated return of the parent corporation’s payment to a partnership, in which the parent is not a partner, is not a “partnership item” within the meaning of section 6231(a)(3) of the Code or an “affected item” within the meaning of section 6231(a)(5), even if another member of the group is a partner in the partnership.

Temporary and proposed regulations under section 6103 of the Code are provided regarding administrative review procedures for certain government agencies and other authorized recipients of tax returns or return information (authorized recipients) whose receipt of returns and return information may be suspended or terminated because they do not maintain proper safeguards. The regulations provide guidance to responsible IRS personnel and authorized recipients as to these administrative procedures.

Temporary and proposed regulations under section 6103 of the Code are provided regarding administrative review procedures for certain government agencies and other authorized recipients of tax returns or return information (authorized recipients) whose receipt of returns and return information may be suspended or terminated because they do not maintain proper safeguards. The regulations provide guidance to responsible IRS personnel and authorized recipients as to these administrative procedures.

Automobile owners and lessees. This procedure provides owners and lessees of passenger automobiles (including trucks, vans, and electric automobiles) with tables detailing the limitations on depreciation deductions for passenger automobiles first placed in service during calendar year 2006 and the amounts to be included in income for passenger automobiles first leased during calendar year 2006.

This document withdraws a proposed regulation (REG-103829-99, 2002-2 C.B. 59) regarding the definition of highway vehicle.



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