[Code of Federal Regulations] [Title 26, Volume 11] [Revised as of April 1, 2004] From the U.S. Government Printing Office via GPO Access [CITE: 26CFR1.1367-3] [Page 750-751] TITLE 26--INTERNAL REVENUE CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) PART 1_INCOME TAXES--Table of Contents Sec. 1.1367-3 Effective date and transition rule. Except for Sec. 1.1367-1(f), (h) Example 2 and Example 5, and (j), Sec. Sec. 1.1367-1 and 1.1367-2 apply to taxable years of the corporation beginning on or after January 1, 1994. Section 1.1367-1(f), (h) Example 2 and Example 5, and (j) apply [[Page 751]] only to taxable years of the corporation beginning on or after August 18, 1998. For taxable years beginning before January 1, 1994, and taxable years beginning on or after January 1, 1997, and before August 18, 1998, the basis of a shareholder's stock must be determined in a reasonable manner, taking into account the statute and legislative history. Except for Sec. 1.1367-1(f), (h) Example 2 and Example 5, and (j), return positions consistent with Sec. Sec. 1.1367-1 and 1.1367-2 are reasonable for taxable years beginning before January 1, 1994. Return positions consistent with Sec. 1.1367-1(f), (h) Example 2 and Example 5, and (j) are reasonable for taxable years beginning on or after January 1, 1997, and before August 18, 1998. [T.D. 8852, 64 FR 71649, Dec. 22, 1999]