potentially abusive situation
Defined in 1 place of the United States Code.
For purposes of subparagraph (A), the term “potentially abusive situation” means—
(i) a tax shelter (as defined in section 6662(d)(2)(C)(ii)),1 and
(ii) any other situation which, by reason of—
(I) recent sales transactions,
(II) nonrecourse financing,
(III) financing with a term in excess of the economic life of the property, or
(IV) other circumstances,
is of a type which the Secretary specifies by regulations as having potential for tax avoidance.
Source
- 1994–199626 U.S.C. § 1274Internal Revenue Code · Determination of issue price in the case of certain debt instruments issued for property · for purposes of this section
For purposes of subparagraph (A), the term “potentially abusive situation” means—
(i) a tax shelter (as defined in section 6662(d)(2)(C)(ii)), and
(ii) any other situation which, by reason of—
(I) recent sales transactions,
(II) nonrecourse financing,
(III) financing with a term in excess of the economic life of the property, or
(IV) other circumstances,
Source
- 2018–present26 U.S.C. § 1274Internal Revenue Code · Determination of issue price in the case of certain debt instruments issued for property · for purposes of this section
For purposes of subparagraph (A), the term "potentially abusive situation" means—
(i) a tax shelter (as defined in section 6662(d)(2)(C)(ii)), and
(ii) any other situation which, by reason of—
(I) recent sales transactions,
(II) nonrecourse financing,
(III) financing with a term in excess of the economic life of the property, or
(IV) other circumstances,
is of a type which the Secretary specifies by regulations as having potential for tax avoidance.
Source
- 2018–202626 U.S.C. § 1274Internal Revenue Code · Determination of issue price in the case of certain debt instruments issued for property · for purposes of this section
For purposes of subparagraph (A), the term “potentially abusive situation” means—
(i) a tax shelter (as defined in section 6662(d)(2)(C)(iii)),1 and
(ii) any other situation which, by reason of—
(I) recent sales transactions,
(II) nonrecourse financing,
(III) financing with a term in excess of the economic life of the property, or
(IV) other circumstances,
Source
- 201326 U.S.C. § 1274Internal Revenue Code · Determination of issue price in the case of certain debt instruments issued for property · for purposes of this section
For purposes of subparagraph (A), the term "potentially abusive situation" means—
(i) a tax shelter (as defined in section 6662(d)(2)(C)(iii)),1 and
(ii) any other situation which, by reason of—
(I) recent sales transactions,
(II) nonrecourse financing,
(III) financing with a term in excess of the economic life of the property, or
(IV) other circumstances,
is of a type which the Secretary specifies by regulations as having potential for tax avoidance.
Source
- 2005–201826 U.S.C. § 1274Internal Revenue Code · Determination of issue price in the case of certain debt instruments issued for property · for purposes of this section
For purposes of subparagraph (A), the term “potentially abusive situation” means—
(i) a tax shelter (as defined in section 6662(d)(2)(C)(iii)), and
(ii) any other situation which, by reason of—
(I) recent sales transactions,
(II) nonrecourse financing,
(III) financing with a term in excess of the economic life of the property, or
(IV) other circumstances,
is of a type which the Secretary specifies by regulations as having potential for tax avoidance.
Source
- 1996–200526 U.S.C. § 1274Internal Revenue Code · Determination of issue price in the case of certain debt instruments issued for property · for purposes of this section