of proof in respect of such issue shall be upon the Commissioner to the same ..... or not such penalty or loss is actually imposed upon the taxpayer). For ..... upon the Commissioner to the same extent as he bears the burden of proof in

consideration agreed upon between FNMA and the initial holder for the

debt upon the occurrence of certain events, paragraph (m) for the ..... reallocated in accordance with paragraph (j) of this section upon the occurrence

interest. Upon repaying the debt, the remaining $1,920 ($2,400−$480) in ..... lien upon the general assets of the taxpayer or by a security interest, such

)(1)(iv)(B) of this section) applies upon the disposition of the machinery ..... upon the sale or other disposition of the factored receivable) over the

or loss upon the disposition of interests in a partnership, and the ..... paragraph (o)(8) of this section. (3) Partner basis adjustment upon ..... recognizes gain or loss upon the disposition of stock of the S corporation, and the ..... 6—(i) Facts. In Year 1, X, Y, and Z formed partnership PRS. Upon

upon expiration of the lease. A may allocate a portion of the $60,000 ..... is a question of fact, and the answer depends upon an examination of all ..... depend solely upon the statements of the taxpayer at the time he acquired

deduction shall be subject to the limitations upon capital losses described in ..... section does not apply to any loss upon the worthlessness of any security ..... Corporation, any loss sustained by X Corporation upon the worthlessness of such ..... Corporation upon the worthlessness of the stock of Z Corporation shall be deducted in ..... loss sustained by X Corporation upon the worthlessness of such stock shall be

secondary obligor upon) a debt obligation. Subject to the provisions of paragraphs ..... obligor upon) a debt obligation. Subject to the provisions of paragraphs (c ..... legal duty upon the taxpayer to make the payment (except that legal action need ..... taxpayer would not be called upon to pay the debt (subject to such agreement

the taxpayer and a rate based upon a life permitted by this section. In ..... depreciation shall be based upon the class life (or individual life if the taxpayer ..... determined based upon the remaining life of the class (or individual ..... upon the class life (or individual life if the taxpayer assigns such lives in ..... determined by using a rate based upon a life not less than the class life, or