...of 1969, Pub. L. 91-172, 83 Stat. 487 (Dec. 30, 1969), provides legislative authority to respondent to determine whether "an interest in a corporation is to be treated for purposes of this title as stock or indebtedness." (Emphasis added.) This extremely broad grant...

..."(a) AUTHORITY To PRESCRIBE REGULATIONS. — The Secretary or his delegate is authorized to prescribe such regulations as may be necessary or appropriate...whether an interest in a corporation is to be treated for purposes of this title as stock or indebtedness. "(b) FACTORS. — The regulations prescribed under...

...OR INDEBTEDNESS. (a) AUTHORITY To PRESCRIBE REGULATIONS.— The Secretary is authorized to prescribe such regulations as may be necessary or appropriate...whether an interest in a corporation is to be treated for purposes of this title as stock or indebtedness. (b) FACTORS.— The regulations prescribed under...

...of 1969, Pub. L. 91-172, 83 Stat. 487 (Dec. 30, 1969) , provides legislative authority to respondent to determine whether "an interest in a corporation is to be treated for purposes of this title as stock or indebtedness." (Emphasis added.) This extremely broad grant...

...and Reform 691. «115 Cong. Rec. S. 37, 633. at 635-638 (Dec. 8. 1969) (remarks of Senator Kennedy). whether an interest in a corporation is to be treated as stock or indebtedness. The section sets forth factors which the regulations may encompass. The list of factors...

...385, enacted in 1969, authorizing the Secretary of the Treasury to prescribe appropriate regulations to determine whether an interest in a corporation is to be treated as stock or indebtedness. The section sets forth factors which the regulations may encompass. The list of factors...

...385, enacted in 1969, authorizing the Secretary of the Treasury to prescribe appropriate regulations to determine whether an interest in a corporation is to be treated as stock or indebtedness. The section sets forth factors which the regulations may encompass. The list of factors...

...an individual to leave the foreign country before meeting the time requirements. The Act authorizes the Treasury Department to issue such regulations as may be necessary or appropriate to carry out the purposes of these provisions, including regulations providing rules for cases in which...

...an individual to leave the foreign country before meeting the time requirements. The Act authorizes the Treasury Department to issue such regulations as may be necessary or appropriate to carry out the purposes of these provisions, including regulations providing rules for cases in which...

...comprehensive debt-equity scheme. Congress in Section 385 authorized the Secretary of the Treasury to prescribe such regulations as may be necessary or appropriate...interest in a corporation is to be treated as stock or indebtedness. However, although the issue is the subject of continuing debate, many contend that neither...