26 C.F.R. § 1.1502-0

Effective/applicability dates

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(a) In general. Except as provided in paragraph (b) of this section, the consolidated return regulations (as defined in § 1.1502-1(g)) are applicable to taxable years beginning after December 31, 1965.

(b) Exceptions. The applicability date described in paragraph (a) of this section does not apply to any provision of the consolidated return regulations with an applicability or effective date different than the date provided by paragraph (a) of this section.

[T.D. 10018, 89 FR 106852, Dec. 30, 2024]
Notes of Decisions
Cited in 10 cases, 1973–2020 · leading case: Gottesman & Co. v. Comm'r, 77 T.C. 1149 (Tax Ct. 1981).
Gottesman & Co. v. Comm'r, 77 T.C. 1149 (Tax Ct. 1981). · cites it 10× “Respondent asserts that these regulations dealt with the manner in which the accumulated earnings tax ( sec.”
S. Pac. Co. v. Comm'r, 84 T.C. 375 (Tax Ct. 1985). · cites it 18× “362 , were made effective only with respect to taxable years beginning after December 31, 1965.”
Rodriguez v. Fed. Deposit Ins. Corp., 140 S. Ct. 713 (2020). “§ 1502 ; 26 CFR § 1.1502-0 et seq. (2019). These regulations are pretty punctilious about ensuring the government gets all the taxes due from corporate group members.”
Int'l Tel. & Tel. Corp. etc. v. Comm'r, 77 T.C. 60 (Tax Ct. 1981). · cites it 2× “We also note that respondent's regulations effective for taxable years commencing with 1966 provide specifically for the computation to be made on a separate rather than aggregate basis.”
S. Pac. Co. v. Comm'r, 84 T.C. 395 (Tax Ct. 1985). · cites it 2× “1502-0(a), Income Tax Regs. Thus, for the years with which we are concerned in this proceeding, calendar years 1966 through 1968, the revised regulations govern.”
Ambac Indus., Inc. v. Comm'r, 59 T.C. 670 (Tax Ct. 1973). · cites it 4× “The regulations applicable to taxable years beginning before Jan. 1, 1966, were redesignated as secs.”
State Farm Mut. Auto. Ins. Co. v. Comm'r, 130 T.C. 263 (Tax Ct. 2008). · cites it 2× “1502-0 through 1.1502-80, Income Tax Regs. ).”
Globe Prods. Corp. v. Comm'r, 72 T.C. 609 (Tax Ct. 1979). · cites it 2× “1502-0(b), Income Tax Regs. ↩ 12. Petitioner cites secs.”
Daron Indus., Inc. v. Comm'r, 62 T.C. 847 (Tax Ct. 1974). · cites it 8× “These provisions are applicable only to taxable years beginning before Jan.”
United States Steel Corp. v. Comm'r, 36 T.C.M. 1152 (Tax Ct. 1977). “The new regulations are applicable to taxable years beginning after December 31, 1965. The old regulations, applicable to taxable years beginning before January 1, 1966, were redesignated as sections 1.”
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