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SECTION 2. BACKGROUND

Internal Revenue Bulletin 2001-23 · 2026-10-03 edition · updated 2026-10-04 · United States

(1) Taxpayers that establish a busi-

ness purpose (2) Taxpayers that are deemed to have

amination, before an area office, or before a federal court (1) Taxpayers under examination (2) Taxpayers before an area office (3) Taxpayers before a federal

court

established a business purpose .03 Natural business year

(1) Annual business cycle test (2) Seasonal business test (3) 25-percent gross receipts test .04 General terms and conditions

(1) Short period tax return (2) Subsequent year tax returns (3) Book conformity (4) Changes in natural business year (5) 52-53-week taxable years (6) Creation of net operating loss or

capital loss (7) Creation of general business

credits .05 Additional terms, conditions, and

adjustments (1) Substantial distortion (2) Deferral of substantial pass-

through income (3) Special rule for certain pass-

through entities (4) Use of expiring NOLs, CLs, and

credits (5) Concurrent change for related

entities (6) Other terms, conditions, and ad-

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▸Contents — Internal Revenue Bulletin 2001-23
Internal Revenue Bulletin 2001-23

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