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Section 1374 Effective Dates; Correction

---
identifier: "/us/fr/05-1734"
source: "fr"
legal_status: "authoritative_unofficial"
title: "Section 1374 Effective Dates; Correction"
title_number: 0
title_name: "Federal Register"
section_number: "05-1734"
section_name: "Section 1374 Effective Dates; Correction"
positive_law: false
currency: "2005-02-01"
last_updated: "2005-02-01"
format_version: "1.1.0"
generator: "[email protected]"
agency: "Treasury Department"
document_number: "05-1734"
document_type: "rule"
publication_date: "2005-02-01"
agencies:
  - "Treasury Department"
  - "Internal Revenue Service"
cfr_references:
  - "26 CFR Part 1"
rin: "1545-BD99"
fr_citation: "70 FR 5044"
fr_volume: 70
docket_ids:
  - "TD 9170"
effective_date: "2004-12-22"
fr_action: "Correcting amendment."
---

#  transactions (temporary).

**AGENCY:**

Internal Revenue Service (IRS), Treasury.

**ACTION:**

Correcting amendment.

**SUMMARY:**

This document corrects temporary regulations (TD 9170) that were published in the *Federal Register* on Wednesday, December 22, 2004 (69 FR 76612), that provide guidance concerning the applicability of section 1374 to S corporations that acquire assets in carryover basis transactions from C corporations on or after December 27, 1994, and to certain corporations that terminate S  corporation status and later elect again to become S corporations.

**DATES:**

This document is effective on December 22, 2004.

**FOR FURTHER INFORMATION CONTACT:**

Stephen R. Cleary, (202) 622-7750 (not a toll-free number).

**SUPPLEMENTARY INFORMATION:**

**Background**

The final and temporary regulations (TD 9170) that is the subject of this correction are under 1374 of the Internal Revenue Code.

**Need for Correction**

As published, the final and temporary regulations (TD 9170) contains an error that may prove to be misleading and are in need of clarification.

**List of Subjects in 26 CFR Parts 1**

Income Tax, Reporting and recordkeeping requirements.

**Correction of Publication**

**26 CFR Part 1**

Accordingly, 26 CFR Part 1 is corrected by making the following correcting amendment:

**PART 1—INCOME TAXES**

*Paragraph 1.* The authority citation for part 1 continues to read in part as follows:

**Authority:**

26 U.S.C. 7805 * * *

**26 CFR Part 1**

2. In § 1.1374-8T, the section heading, and paragraphs (a)(1) and (a)(2) are revised to read as follows:

§ 1.1374-8T 1374(d)(8)

(a)(1) (Reserved) For further guidance see § 1.1374-8(a).

(2) Section 1374(d)(8) applies to any § 1.1374(d)(8) transaction, as defined in paragraph (a)(1) of this section, that occurs on or after December 27, 1994, without regard to the date of the corporation's election to be an S corporation under section 1362.

Cynthia E. Grigsby,

Acting Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedures and Administration).