§444. Election of taxable year other than required taxable year — Inbound Citations
26 U.S.C. § 444
Cited by 10 provisions in release 119-102.
Citations to 26 U.S.C. § 444 as a whole
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(1) an election by a personal service corporation under section 444 is in effect for a taxable year, and
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(e) No net operating loss carryback shall be allowed to (or from) any taxable year of a personal service corporation to which an election under section 444 applies.
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(1) an election under section 444 is in effect for the taxable year, and
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(A) an election under section 444 is terminated effective with respect to any year, or
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(4) The applicable percentage is the percentage determined in accordance with the following table:Notwithstanding the preceding provisions of this paragraph, the applicable percentage for any partnership or S corporation shall be 100 percent unless more than 50 percent of such entity’s net income for the short taxable year which would have resulted if the entity had not made an election under section 444 would have been allocated to partners or shareholders who would have been entitled to the benefits of section 806(e)(2)(C) of the Tax Reform Act of 1986 with respect to such income.
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(3) Each partnership or S corporation which makes an election under section 444 shall include on any required return or statement such information as the Secretary shall prescribe as is necessary to carry out the provisions of this section.
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(C) If any partnership or S corporation willfully fails to comply with the requirements of this section, section 444 shall cease to apply with respect to such partnership or S corporation.
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(g) The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the provisions of this section and section 280H, including regulations providing for appropriate adjustments in the application of this section and sections 280H and 444 in cases where—(1) 2 or more applicable election years begin in the same calendar year, or(2) the base year is a taxable year of less than 12 months.
Citations to §444(b)(4)
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(A) The term “deferral period” has the meaning given to such term by section 444(b)(4).
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(1) The term “deferral period” has the meaning given to such term by section 444(b)(4).