New Horizons For The Retarded, Inc.

2 Cited authorities

  1. Section 6621 - Determination of rate of interest

    26 U.S.C. § 6621   Cited 1,873 times   23 Legal Analyses
    Applying a higher interest rate to past liabilities resulting from tax-motivated transactions
  2. Section 1274 - Determination of issue price in the case of certain debt instruments issued for property

    26 U.S.C. § 1274   Cited 66 times   15 Legal Analyses

    (a) In general In the case of any debt instrument to which this section applies, for purposes of this subpart, the issue price shall be- (1) where there is adequate stated interest, the stated principal amount, or (2) in any other case, the imputed principal amount. (b) Imputed principal amount For purposes of this section- (1) In general Except as provided in paragraph (3), the imputed principal amount of any debt instrument shall be equal to the sum of the present values of all payments due under