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TABLE OF CONTENTS
FINAL TEMPORARY AND PROPOSED REGULATIONS
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additional depreciation adjusted basis allocated amended Reg amount of gain amount realized application of section attributable bond computed controlled foreign corporation debt instrument December 31 disposition distribution earnings and profits erty exchange group fair market value following examples foreign corporation gain or loss gain realized gain recognized gift gift tax graph gross income holding period identified included income under section interest Internal Revenue Code issue price January long-term capital gain long-term capital loss ment obligation option ordinary income paragraph partner partnership payment percent portion prop property acquired purchase purposes of section pursuant put option QSB stock qualified qualified intermediary reacquisition real property recognized under section replacement property respect sale or exchange section 1250 property section 1254 costs series E bonds shareholder short-term capital gain sold Special rules stock or securities subdivision subparagraph taxable income taxable years beginning taxpayer tion trade or business transferor treated