Sec. 1502. When the authority to prescribe legislative regulations exists, this Court is not inclined to interfere if the regulations as written support the taxpayer's position. Transco Exploration Co. v. Commissioner, 95 T.C. 373, 383-384 (1990); Idaho First National Bank v. Commissioner, 95 T.C. 185 (1990). In Woods Investment Co. v. Commissioner, 85 T.C. 274 (1985), the taxpayer had four wholly owned subsidiaries with which it filed consolidated returns.
17, 1987) (no recapture of the rehabilitation tax credit upon the grant of a facade easement within the meaning of section 170(h)) in support of its contention that Congress did not intend to penalize taxpayers by limiting the rehabilitation tax credit incentive by the section 170(h) qualified conservation contribution provisions. Notwithstanding the fact that general counsel memoranda have no precedential value, Idaho First National Bank v. Commissioner, 95 T.C. 185, 191 (1990), we note that G.C.M. 39664 indicated that the granting of an easement will generally constitute a disposition under section 47. The House Ways and Means Committee Report states: