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Amount realized, in US federal income tax law, is defined by section 1001(b) of Internal Revenue Code. It is one of two variables in the formula used to compute gains and losses to determine gross income for income tax purposes. The excess of the amount realized over the adjusted basis is the amount of realized gain (if positive) or realized ...
Internal Revenue Code section 1001(c) [1] provides that gains and losses, if realized, are also recognized unless otherwise provided in the Code. This default rule has several exceptions, called "nonrecognition" rules, which are scattered throughout the Code.
According to section 1001(c) of the Internal Revenue Code (IRC § 1001(c)), all realized gains and losses must be recognized "except as otherwise provided in this subtitle." [1] While the general rule of recognition applies in most cases, there are actually several exceptions located throughout the Internal Revenue Code. [2]
Commissioner, 499 U.S. 554, 559 (1991), the Supreme Court, interpreting section 1001(a) of the tax ... This is an unpopular result and the Internal Revenue Service ...
The text of the Internal Revenue Code as published in title 26 of the U.S. Code is virtually identical to the Internal Revenue Code as published in the various volumes of the United States Statutes at Large. [3] Of the 50 enacted titles, the Internal Revenue Code is the only volume that has been published in the form of a separate code.
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Commissioner v. Tufts, 461 U.S. 300 (1983), was a unanimous decision by the United States Supreme Court, which held that when a taxpayer sells or disposes of property encumbered by a nonrecourse obligation exceeding the fair market value of the property sold, the Commissioner of Internal Revenue may require him to include in the “amount realized” the outstanding amount of the obligation ...
A like-kind exchange is a type of "non-recognition provision". According to section 1001(c) of the Internal Revenue Code, all realized gains and losses must be recognized "except as otherwise provided in this subtitle". A like-kind exchange is one of the qualified exceptions, serving as the proto-typical "non-recognition provision".
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