The final repair regulations1 which were similar but not identical to the temporary repair regulations,2 were to be followed by all taxpayers commencing in taxable years beginning on or after January 1, 2014.3 The temporary regulations were to become effective, generally, for taxable years beginning on or after January 1, 2012 but Ann. 2013-7 stated that the effective date for T.D. 9564 would be January 1, 2014.4 That aspect created considerable confusion among taxpayers and tax practitioners. However, one question posed for the various regulations has been – do small taxpayers have to meet the same classification and reporting requirements as large taxpayers? The answer came, not in the regulations, except for a hint,5 but in Rev. Proc. 2014-166 and Rev. Proc. 2014-54.7



To view the content in your browser, please download Adobe Reader or, alternately,
you may Download the file to your hard drive.

NOTE: The latest versions of Adobe Reader do not support viewing PDF files within Firefox on Mac OS and if you are using a modern (Intel) Mac, there is no official plugin for viewing PDF files within the browser window.