Philip Levine, speaking at the corporate tax developments session of the Federal Bar Association Section on Taxation annual meeting, said he was amazed at how many basic questions in subchapter C of the so-called basis recovery regulations remain unanswered. Suggesting that the IRS may re-propose sections of its guidance Mr. Levine continued, “One of the interesting things is that these regs kind of focus on a share-by-share approach and, at least in the consolidated area — which admittedly has different considerations — there’s movement towards thinking about it as an aggregate.”
