Revenue Ruling 2009-25 holds that disallowed interest under § 264(a)(4) reduces earnings and profits for the taxable year in which the interest would have been allowable as a deduction, but for its disallowance under § 264(a)(4). It does not further reduce E&P when the death benefit is received under a life insurance contract.
Revenue Ruling 2009-25 will be in I.R.B. 2009-38, dated September 21, 2009.
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