3. Jacob Wrentham, a 31-year-old single filer, has been noti…

3. Jacob Wrentham, a 31-year-old single filer, has been notified by the IRS that his return is being audited. According to documentation he has received in the mail, the audit is focused solely on Jacob’s timely-filed Form 1040, Line 12. The audit of Jacob’s return is most likely a:

4. On February 10, 2013, the IRS issued Treas. Reg. § 1.385-…

4. On February 10, 2013, the IRS issued Treas. Reg. § 1.385-1T which provided rules pertaining to the analysis of whether an instrument is debt or equity for federal income tax purposes. X Corporation, a sophisticated taxpayer wishes to rely upon the regulation to support its position that a loan it extended to a related party is debt rather than equity. Can it rely upon the regulation for taxable year 2023?