[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]