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Internal Revenue Code Section 409A The Company intends for this Agreement to comply with the Indemnification exception under Section 1.409A-1(b)(10) of the regulations promulgated under the Internal Revenue Code of 1986, as amended (the “Code”), which provides that indemnification of, or the...
(c) (1986). More specifically, the Commissioner relies on the regulations' assertion of authority to reallocate income between related parties even where such reallocations effectively nullify nonrecognition transactions authorized by other sections of the Internal Revenue Code, such as section 351. See...
Wal-mart Stores, Inc. & Subsidiaries, Appellees, v. Commissioner of Internal Revenue, Appellant, 153 F.3d 650 (8th Cir. 1998) case opinion from the U.S. Court of Appeals for the Eighth Circuit
Moreover, we can divine no indication in the legislative history of the Revenue Act as to whether "direct" should be understood to modify all of the nouns that follow it.9In addition, we reject the Commissioner's argument that the Act's legislative history demonstrates that Congress intended ...