well technically no, unless I do an act charity or penance in its place and I am far to focused on posting to do either

and In-N-Out burgers are great^^

 

The resemblance mentions the clue.

 

22058 737-204 Star Peru 20/12/1979 OB-1841-P Active

 

� 276. Certain indirect contributions to political parties

How Current is This?
(a) Disallowance of deduction
No deduction otherwise allowable under this chapter shall be allowed for any amount paid or incurred for�
(1) advertising in a convention program of a political party, or in any other publication if any part of the proceeds of such publication directly or indirectly inures (or is intended to inure) to or for the use of a political party or a political candidate,
(2) admission to any dinner or program, if any part of the proceeds of such dinner or program directly or indirectly inures (or is intended to inure) to or for the use of a political party or a political candidate, or
(3) admission to an inaugural ball, inaugural gala, inaugural parade, or inaugural concert, or to any similar event which is identified with a political party or a political candidate.
(b) Definitions
For purposes of this section�
(1) Political party
The term �political party� means�
(A) a political party;
(B) a National, State, or local committee of a political party; or
(C) a committee, association, or organization, whether incorporated or not, which directly or indirectly accepts contributions (as defined in section 271 (b)(2)) or make expenditures (as defined in section 271 (b)(3)) for the purpose of influencing or attempting to influence the selection, nomination, or election of any individual to any Federal, State, or local elective public office, or the election of presidential and vice-presidential electors, whether or not such individual or electors are selected, nominated, or elected.
(2) Proceeds inuring to or for the use of political candidates
Proceeds shall be treated as inuring to or for the use of a political candidate only if�
(A) such proceeds may be used directly or indirectly for the purpose of furthering his candidacy for selection, nomination, or election to any elective public office, and
(B) such proceeds are not received by such candidate in the ordinary course of a trade or business (other than the trade or business of holding elective public office).
(c) Cross reference
For disallowance of certain entertainment, etc., expenses, see section 274.

 

Randy better not pick post #1 as the winner!

 

The horse shifts around the model.

 

when will the maddness end.

ps I hate tofu

 

kibbles and bits

 

� 277. Deductions incurred by certain membership organizations in transactions with members

How Current is This?
(a) General rule
In the case of a social club or other membership organization which is operated primarily to furnish services or goods to members and which is not exempt from taxation, deductions for the taxable year attributable to furnishing services, insurance, goods, or other items of value to members shall be allowed only to the extent of income derived during such year from members or transactions with members (including income derived during such year from institutes and trade shows which are primarily for the education of members). If for any taxable year such deductions exceed such income, the excess shall be treated as a deduction attributable to furnishing services, insurance, goods, or other items of value to members paid or incurred in the succeeding taxable year. The deductions provided by sections 243, 244, and 245 (relating to dividends received by corporations) shall not be allowed to any organization to which this section applies for the taxable year.
(b) Exceptions
Subsection (a) shall not apply to any organization�
(1) which for the taxable year is subject to taxation under subchapter H or L,
(2) which has made an election before October 9, 1969, under section 456 (c) or which is affiliated with such an organization,
(3) which for each day of any taxable year is a national securities exchange subject to regulation under the Securities Exchange Act of 1934 or a contract market subject to regulation under the Commodity Exchange Act, or
(4) which is engaged primarily in the gathering and distribution of news to its members for publication.

 

I am really tempted to ask some people to run a dos attack on primsux.

 

yes they are

 

The vendor attends.

 

This one simply because its helped so many desperate folks (NOT ME):

 

22059 737-204 COPA Panama 15/01/1980 HP1205CMP Written off

 

� 279. Interest on indebtedness incurred by corporation to acquire stock or assets of another corporation

How Current is This?
(a) General rule
No deduction shall be allowed for any interest paid or incurred by a corporation during the taxable year with respect to its corporate acquisition indebtedness to the extent that such interest exceeds�
(1) $5,000,000, reduced by
(2) the amount of interest paid or incurred by such corporation during such year on obligations
(A) issued after December 31, 1967, to provide consideration for an acquisition described in paragraph (1) of subsection (b), but
(B) which are not corporate acquisition indebtedness.
(b) Corporate acquisition indebtedness
For purposes of this section, the term �corporate acquisition indebtedness� means any obligation evidenced by a bond, debenture, note, or certificate or other evidence of indebtedness issued after October 9, 1969, by a corporation (hereinafter in this section referred to as �issuing corporation�) if�
(1) such obligation is issued to provide consideration for the acquisition of�
(A) stock in another corporation (hereinafter in this section referred to as �acquired corporation�), or
(B) assets of another corporation (hereinafter in this section referred to as �acquired corporation�) pursuant to a plan under which at least two-thirds (in value) of all the assets (excluding money) used in trades and businesses carried on by such corporation are acquired,
(2) such obligation is either�
(A) subordinated to the claims of trade creditors of the issuing corporation generally, or
(B) expressly subordinated in right of payment to the payment of any substantial amount of unsecured indebtedness, whether outstanding or subsequently issued, of the issuing corporation,
(3) the bond or other evidence of indebtedness is either�
(A) convertible directly or indirectly into stock of the issuing corporation, or
(B) part of an investment unit or other arrangement which includes, in addition to such bond or other evidence of indebtedness, an option to acquire, directly or indirectly, stock in the issuing corporation, and
(4) as of a day determined under subsection (c)(1), either�
(A) the ratio of debt to equity (as defined in subsection (c)(2)) of the issuing corporation exceeds 2 to 1, or
(B) the projected earnings (as defined in subsection (c)(3)) do not exceed 3 times the annual interest to be paid or incurred (determined under subsection (c)(4)).
(c) Rules for application of subsection (b)(4)
For purposes of subsection (b)(4)�
(1) Time of determination
Determinations are to be made as of the last day of any taxable year of the issuing corporation in which it issues any obligation to provide consideration for an acquisition described in subsection (b)(1) of stock in, or assets of, the acquired corporation.
(2) Ratio of debt to equity
The term �ratio of debt to equity� means the ratio which the total indebtedness of the issuing corporation bears to the sum of its money and all its other assets (in an amount equal to their adjusted basis for determining gain) less such total indebtedness.
(3) Projected earnings
(A) The term �projected earnings� means the �average annual earnings� (as defined in subparagraph (B)) of�
(i) the issuing corporation only, if clause (ii) does not apply, or
(ii) both the issuing corporation and the acquired corporation, in any case where the issuing corporation has acquired control (as defined in section 368 (c)), or has acquired substantially all of the properties, of the acquired corporation.
(B) The average annual earnings referred to in subparagraph (A) is, for any corporation, the amount of its earnings and profits for any 3-year period ending with the last day of a taxable year of the issuing corporation described in paragraph (1), computed without reduction for�
(i) interest paid or incurred,
(ii) depreciation or amortization allowed under this chapter,
(iii) liability for tax under this chapter, and
(iv) distributions to which section 301 (c)(1) applies (other than such distributions from the acquired to the issuing corporation),
and reduced to an annual average for such 3-year period pursuant to regulations prescribed by the Secretary. Such regulations shall include rules for cases where any corporation was not in existence for all of such 3-year period or such period includes only a portion of a taxable year of any corporation.
(4) Annual interest to be paid or incurred
The term �annual interest to be paid or incurred� means�
(A) if subparagraph (B) does not apply, the annual interest to be paid or incurred by the issuing corporation only, determined by reference to its total indebtedness outstanding, or
(B) if projected earnings are determined under clause (ii) of paragraph (3)(A), the annual interest to be paid or incurred by both the issuing corporation and the acquired corporation, determined by reference to their combined total indebtedness outstanding.
(5) Special rules for banks and lending or finance companies
With respect to any corporation which is a bank (as defined in section 581) or is primarily engaged in a lending or finance business�
(A) in determining under paragraph (2) the ratio of debt to equity of such corporation (or of the affiliated group of which such corporation is a member), the total indebtedness of such corporation (and the assets of such corporation) shall be reduced by an amount equal to the total indebtedness owed to such corporation which arises out of the banking business of such corporation, or out of the lending or finance business of such corporation, as the case may be;
(B) in determining under paragraph (4) the annual interest to be paid or incurred by such corporation (or by the issuing and acquired corporations referred to in paragraph (4)(B) or by the affiliated group of which such corporation is a member) the amount of such interest (determined without regard to this paragraph) shall be reduced by an amount which bears the same ratio to the amount of such interest as the amount of the reduction for the taxable year under subparagraph (A) bears to the total indebtedness of such corporation; and
(C) in determining under paragraph (3)(B) the average annual earnings, the amount of the earnings and profits for the 3-year period shall be reduced by the sum of the reductions under subparagraph (B) for such period.
For purposes of this paragraph, the term �lending or finance business� means a business of making loans or purchasing or discounting accounts receivable, notes, or installment obligations.
(d) Taxable years to which applicable
In applying this section�
(1) First year of disallowance
The deduction of interest on any obligation shall not be disallowed under subsection (a) before the first taxable year of the issuing corporation as of the last day of which the application of either subparagraph (A) or subparagraph (B) of subsection (b)(4) results in such obligation being corporate acquisition indebtedness.
(2) General rule for succeeding years
Except as provided in paragraphs (3), (4), and (5), if an obligation is determined to be corporate acquisition indebtedness as of the last day of any taxable year of the issuing corporation, it shall be corporate acquisition indebtedness for such taxable year and all subsequent taxable years.
(3) Redetermination where control, etc., is acquired
If an obligation is determined to be corporate acquisition indebtedness as of the close of a taxable year of the issuing corporation in which clause (i) of subsection (c)(3)(A) applied, but would not be corporate acquisition indebtedness if the determination were made as of the close of the first taxable year of such corporation thereafter in which clause (ii) of subsection (c)(3)(A) could apply, such obligation shall be considered not to be corporate acquisition indebtedness for such later taxable year and all taxable years thereafter.
(4) Special 3-year rule
If an obligation which has been determined to be corporate acquisition indebtedness for any taxable year would not be such indebtedness for each of any 3 consecutive taxable years thereafter if subsection (b)(4) were applied as of the close of each of such 3 years, then such obligation shall not be corporate acquisition indebtedness for all taxable years after such 3 consecutive taxable years.
(5) 5 percent stock rule
In the case of obligations issued to provide consideration for the acquisition of stock in another corporation, such obligations shall be corporate acquisition indebtedness for a taxable year only if at some time after October 9, 1969, and before the close of such year the issuing corporation owns 5 percent or more of the total combined voting power of all classes of stock entitled to vote of such other corporation.
(e) Certain nontaxable transactions
An acquisition of stock of a corporation of which the issuing corporation is in control (as defined in section 368 (c)) in a transaction in which gain or loss is not recognized shall be deemed an acquisition described in paragraph (1) of subsection (b) only if immediately before such transaction
(1) the acquired corporation was in existence, and
(2) the issuing corporation was not in control (as defined in section 368(c)) of such corporation.
(f) Exemption for certain acquisitions of foreign corporations
For purposes of this section, the term �corporate acquisition indebtedness� does not include any indebtedness issued to any person to provide consideration for the acquisition of stock in, or assets of, any foreign corporation substantially all of the income of which, for the 3-year period ending with the date of such acquisition or for such part of such period as the foreign corporation was in existence, is from sources without the United States.
(g) Affiliated groups
In any case in which the issuing corporation is a member of an affiliated group, the application of this section shall be determined, pursuant to regulations prescribed by the Secretary, by treating all of the members of the affiliated group in the aggregate as the issuing corporation, except that the ratio of debt to equity of, projected earnings of, and annual interest to be paid or incurred by any corporation (other than the issuing corporation determined without regard to this subsection) shall be included in the determinations required under subparagraphs (A) and (B) of subsection (b)(4) as of any day only if such corporation is a member of the affiliated group on such day, and, in determining projected earnings of such corporation under subsection (c)(3), there shall be taken into account only the earnings and profits of such corporation for the period during which it was a member of the affiliated group. For purposes of the preceding sentence, the term �affiliated group� has the meaning assigned to such term by section 1504 (a), except that all corporations other than the acquired corporation shall be treated as includible corporations (without any exclusion under section 1504 (b)) and the acquired corporation shall not be treated as an includible corporation.
(h) Changes in obligation
For purposes of this section�
(1) Any extension, renewal, or refinancing of an obligation evidencing a preexisting indebtedness shall not be deemed to be the issuance of a new obligation.
(2) Any obligation which is corporate acquisition indebtedness of the issuing corporation is also corporate acquisition indebtedness of any corporation which becomes liable for such obligation as guarantor, endorser, or indemnitor or which assumes liability for such obligation in any transaction.
(i) Certain obligations issued after October 9, 1969
For purposes of this section, an obligation shall not be corporate acquisition indebtedness if issued after October 9, 1969, to provide consideration for the acquisition of�
(1) stock or assets pursuant to a binding written contract which was in effect on October 9, 1969, and at all times thereafter before such acquisition, or
(2) stock in any corporation where the issuing corporation, on October 9, 1969, and at all times thereafter before such acquisition, owned at least 50 percent of the total combined voting power of all classes of stock entitled to vote of the acquired corporation.
(j) Effect on other provisions
No inference shall be drawn from any provision in this section that any instrument designated as a bond, debenture, note, or certificate or other evidence of indebtedness by its issuer represents an obligation or indebtedness of such issuer in applying any other provision of this title.