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Introduction

SECTION 3. PROCEDURE

Internal Revenue Bulletin 2005-37 · 2026-10-03 edition · updated 2026-10-04 · United States

Rev. Proc. 2005–3 is amplified by adding the following to section 3.01: Sections 61, 451 and 1001. Gross Income Defined; General Rule for Taxable Year of Inclusion; Determination of Amount and Recognition of Gain or Loss. Whether, under authorization by an appropriate State agency to recover certain costs pursuant to State specified cost recovery legislation, any investor-owned utility company realizes income upon: (1) the creation of an intangible property right; (2) the transfer of that intangible property right; or (3) the securitization of the intangible property right.

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▸Contents — Internal Revenue Bulletin 2005-37

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