INCOME TAX

Rev. Rul. 2001–6, page 491. Deductibility of payments in redemption of stock held by an employee stock ownership plan (ESOP). Payments in redemption of stock held by an ESOP that are used to make distributions to terminating ESOP participants are not deductible and do not constitute “applicable dividends” under section 404(k)(1) of the Code.

T.D. 8919, page 505. REG–119352–00, page 525. Temporary and proposed regulations provide guidance under section 1502 of the Code regarding the time for filing an application for a tentative carryback adjustment by consolidated groups and by certain new members of consolidated groups. A public hearing on the proposed regulations is scheduled for April 26, 2001.

T.D. 8922, page 508. REG–121928–98, page 520. Temporary and proposed regulations provide guidance relating to the recovery of attorney’s fees and other costs where a qualified offer has been made under section 7430 of the Code. A public hearing on the proposed regulations is scheduled for May 23, 2001.

T.D. 8923, page 485. Final regulations under sections 170, 2055, and 2522 of the Code relate to the definition of a guaranteed annuity interest and a unitrust interest for purposes of the gift, estate, and income tax charitable deductions.