[Code of Federal Regulations]
[Title 26, Volume 1]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.269-7]

[Page 593]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.269-7  Relationship of section 269 to sections 382 and 383 after 
the Tax Reform Act of 1986.

    Section 269 and Sec. Sec. 1.269-1 through 1.269-5 may be applied to 
disallow a deduction, credit, or other allowance notwithstanding that 
the utilization or amount of a deduction, credit, or other allowance is 
limited or reduced under section 382 or 383 and the regulations 
thereunder. However, the fact that the amount of taxable income or tax 
that may be offset by a deduction, credit, or other allowance is limited 
under section 382(a) or 383 and the regulations thereunder is relevant 
to the determination of whether the principal purpose of an acquisition 
is the evasion or avoidance of Federal income tax.

[T.D. 8388, 57 FR 346, Jan. 6, 1992]