Extension of Time for Election to Exclude Income Resulting from Discharge of Qualified Real Property Business Indebtedness

IRS Private Letter Ruling 201212002

This letter responds to your letter requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an election under § 108(c)(3)(C) of the Internal Revenue Code.

Specifically, you have requested an extension of time to make an election under § 108(c)(3)(C) and §1.108-5(b) of the Income Tax Regulations, to exclude income resulting from the discharge of qualified real property business indebtedness and to reduce the basis of depreciable real property, effective for Taxpayer’s Year 1 tax return.

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