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For purposes of this section, any interest of a partner in a partnership shall be treated as depreciable property to the extent of such partner’s proportionate interest in the depreciable property held by such partnership.
- Repealed. Pub. L. 96–589, 6
Repeal effective Oct. 1, 1979, but not to apply to...
- Repealed. Pub. L. 96–589, 6
Section 1017 (a) provides the general rule that if (1) an amount is excluded from gross income under Sections (a), (b) (2) (E), (b) (5), or (c) (1) of Section 108, any portion of that amount is to be applied to reduce basis, then that portion is applied in reduction of basis of any property held by the taxpayer at the beginning of the taxable ye...
For basis reductions under section 108(b)(5) and basis reductions relating to qualified farm indebtedness, a taxpayer may elect under sections 1017(b) (3)(E) and (4)(C), respectively, to treat real property described in section 1221(1) as depreciable property.
Section 1017(a) provides that when any portion of COD income excluded from gross income under section 108(a) is to be applied to reduce basis, then such portion shall be applied to reduce the basis of any property held by the taxpayer at the beginning of the taxable year following the taxable year
Internal Revenue Code Section 1017 Discharge of indebtedness (a) General rule. If- (1) an amount is excluded from gross income under subsection (a) of section 108 (relating to discharge of indebtedness), and (2) under subsection (b)(2)(E) , (b)(5) , or (c)(1) of section 108 , any portion of such amount is to be applied to reduce basis,
For purposes of this section, any interest of a partner in a partnership shall be treated as depreciable property to the extent of such partner's proportionate interest in the depreciable property held by such partnership.
1 Απρ 2023 · Consider the following example: Example 1: Corporation D undergoes a debt workout in which $500 million of debt is discharged in exchange for (1) new debt of $200 million, (2) cash of $50 million raised from new senior creditors, and (3) preferred equity in Corporation D of $150 million.
