[Code of Federal Regulations]
[Title 26, Volume 2]
[Revised as of April 1, 2002]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.148-10A]

[Page 724]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
COMPUTATION OF TAXABLE INCOME--Table of Contents
 
Sec. 1.148-10A  Anti-abuse rules and authority of Commissioner.

    (a) through (b)(1) [Reserved]. For guidance see Sec. 1.148-10.
    (b)(2) Application. The provisions of Sec. 1.148-10(b) only apply to 
the portion of an issue that, as a result of actions taken (or actions 
not taken) after the issue date, overburdens the market for tax-exempt 
bonds, except that for an issue that is reasonably expected as of the 
issue date to overburden the market, those provisions apply to all of 
the gross proceeds of the issue.
    (c) through (c)(2)(viii) [Reserved]. For guidance see Sec. 1.148-10.
    (c)(2)(ix) For purposes of Sec. 1.148-10(c)(2), excess gross 
proceeds do not include gross proceeds allocable to fees for a qualified 
hedge for the refunding issue.

[T.D. 8538, 59 FR 24046, May 10, 1994. Redesignated by T.D. 8718, 62 FR 
25507, May 9, 1997]