[Federal Register Volume 60, Number 137 (Tuesday, July 18, 1995)]
[Proposed Rules]
[Pages 36755-36756]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 95-16971]



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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[CO-24-95]
RIN 1545-AT51


Consolidated Groups--Intercompany Transactions and Related Rules

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking by cross-reference to temporary 
regulations and notice of public hearing.

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SUMMARY: In the Rules and Regulations section of this issue of the 
Federal Register, the IRS is issuing temporary regulations that provide 
rules for disallowing loss and excluding gain for certain dispositions 
and other transactions involving stock of the common parent of a 
consolidated group. The text of those temporary regulations also serves 
as the text of these proposed regulations. This document also provides 
notice of a public hearing on these proposed regulations.

DATES: Written comments must be received by October 16, 1995. Outlines 
of topics to be discussed at the public hearing scheduled for November 
16, 1995 must be received by October 26, 1995.

ADDRESSES: Send submissions to: CC:DOM:CORP:T:R (CO-24-95), room 5228, 
Internal Revenue Service, P.O.B. 7604, Ben Franklin Station, 
Washington, DC 20044. In the alternative, submissions may be hand 
delivered between the hours of 8 a.m. and 5 p.m. to: CC:DOM:CORP:T:R 
(CO-24-95), Courier's Desk, Internal Revenue Service, 1111 Constitution 
Avenue, NW., Washington, DC. The hearing will be held in the IRS 
Auditorium, 1111 Constitution Avenue, NW, Washington, DC.

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Victor Penico, (202) 622-7750; concerning submissions and the hearing, 
Christina Vazquez, (202) 622-7180 (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

    Temporary regulations in the Rules and Regulations section of this 
issue of the Federal Register amend the Income Tax Regulations (26 CFR 
part 1) relating to section 1502. The temporary regulations provide 
rules for disallowing loss and excluding gain for certain dispositions 
and other transactions involving stock of the common parent of a 
consolidated group.
    The text of those temporary regulations also serves as the text of 
these proposed regulations. The preamble to the temporary regulations 
explains the temporary regulations.

Special Analysis

    Is has been determined that this notice of proposed rulemaking is 
not a significant regulatory action as defined in EO 12866. Therefore, 
a regulatory assessment is not required. It also has been determined 
that section 553(b) of the Administrative Procedure Act (5 U.S.C. 
chapter 5) and the Regulatory Flexibility Act (5 U.S.C. chapter 6) do 
not apply to these regulations, and, therefore, a Regulatory 
Flexibility Analysis is not required. Pursuant to section 7805(f) of 
the Internal Revenue Code, this notice of proposed rulemaking will be 
submitted to the Chief Counsel for Advocacy of the Small Business 
Administration for comment on its impact on small business.

Comments and Public Hearing

    Before these proposed regulations are adopted as final regulations, 
consideration will be given to any written comments (a signed original 
and eight (8) copies) that are submitted timely to the IRS. All 
comments will be available for public inspection and copying.
    A public hearing has been scheduled for November 16, 1995 at 10 
a.m., in the 

[[Page 36756]]
IRS Auditorium. Because of access restrictions, visitors will not be 
admitted beyond the Internal Revenue Building lobby more than 15 
minutes before the hearing starts.
    The rules of 26 CFR 601.601(a)(3) apply to the hearing.
    Persons who wish to present oral comments at the hearing must 
submit written comments by October 26, 1995 and submit an outline of 
the topics (signed original and eight (8) copies) to be discussed by 
October 26, 1995.
    A period of 10 minutes will be allotted to each person for making 
comments.
    An agenda showing the scheduling of the speakers will be prepared 
after the deadline for receiving outlines has passed. Copies of the 
agenda will be available free of charge at the hearing.

Drafting Information

    These regulations were drafted by personnel from the Treasury 
Department and the IRS.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Proposed Amendments to the Regulations

    Accordingly, 26 CFR part 1 is proposed to be amended as follows:

PART 1--INCOME TAXES

    Paragraph 1. The authority citation for part 1 continues to read in 
part as follows:

    Authority: 26 U.S.C. 7805 * * *

    Par. 2. In Sec. 1.1502-13, paragraph (f)(6) is added to read as 
follows:


Sec. 1.1502-13  Intercompany transactions.

[The text of proposed paragraph (f)(6) is the same as the text of 
Sec. 1.1502-13T(f)(6) published elsewhere in this issue of the Federal 
Register].
Michael P. Dolan,
Acting Commissioner of Internal Revenue.
[FR Doc. 95-16971 Filed 7-12-95; 12:56 pm]
BILLING CODE 4830-01-U