[Code of Federal Regulations]
[Title 26, Volume 2]
[Revised as of April 1, 2003]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.148-10A]
[Page 736]
TITLE 26--INTERNAL REVENUE
CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY
(CONTINUED)
PART 1--INCOME TAXES--Table of Contents
Sec. 1.148-10A Anti-abuse rules and authority of Commissioner.
(a) through (b)(1) [Reserved]. For guidance see Sec. 1.148-10.
(b)(2) Application. The provisions of Sec. 1.148-10(b) only apply to
the portion of an issue that, as a result of actions taken (or actions
not taken) after the issue date, overburdens the market for tax-exempt
bonds, except that for an issue that is reasonably expected as of the
issue date to overburden the market, those provisions apply to all of
the gross proceeds of the issue.
(c) through (c)(2)(viii) [Reserved]. For guidance see Sec. 1.148-10.
(c)(2)(ix) For purposes of Sec. 1.148-10(c)(2), excess gross
proceeds do not include gross proceeds allocable to fees for a qualified
hedge for the refunding issue.
[T.D. 8538, 59 FR 24046, May 10, 1994. Redesignated by T.D. 8718, 62 FR
25507, May 9, 1997]