4/7/2024 0 Comments Irc 267![]() Ĭertain family members qualify under Section 267(b) as being related parties. Commissioner, for example, the Tax Court denied a deduction to a party for the loss he sustained in a foreclosure proceeding and which resulted in a judicial sale of his property to members of his family. In addition, the rule prohibiting a loss on a sale or transfer is not dependent upon whether the transfer is a voluntary one. The fact that a transaction may have been bona fide and at fair market value is immaterial. Under Section 267, when a taxpayer sells or transfers property at a loss to a person who qualifies as a related family member under Section 267(b), Section 267(a) prohibits the recognition of the loss. Section 267(b) is referenced in 79 sections throughout the Internal Revenue Code as well as 175 state law provisions for the definition of “related taxpayers.” This article focuses exclusively on Section 267(b)(1) disqualified family members. ![]()
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