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Basis reduction due to discharge of indebtedness: proposed regs.
The Tax Adviser
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June 1, 1997|
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COPYRIGHT 1997 American Institute of CPA's. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group.
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On Jan. 7, 1997, the IRS issued proposed regulations under Sec. 1017, specifying the manner and timing of reductions to asset basis accompanying the exclusion of discharge of indebtedness (COD) income from gross income; specific rules for applying Sec. 1017 to partnerships are also provided. The regulations are proposed to be effective on or after the date final regulations are published.
Background
Sec. 108(a) generally excludes COD income from gross income if:
* The debtor taxpayer is in a Title 11 case (bankruptcy);
* The debtor ...
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