Bulletin No. 2005-15 April 11, 2005

T.D. 9192, page 866. Final regulations under section 1502 of the Code provide guidance concerning the determination of the tax attributes that are available for reduction and the method for reducing those attributes when a member of a consolidated group excludes discharge of indebtedness income from gross income under section 108.

T.D. 9193, page 862. Final regulations under section 704 of the Code clarify that if section 704(c) property is sold for an installment obligation, the installment obligation is treated as the contributed property for purposes of applying sections 704(c) and 737. Likewise, if the contributed property is a contract, such as an option to acquire property, the property acquired pursuant to the contract is treated as the contributed property for these purposes.

Announcement 2005–25, page 891. This document contains a correction to final regulations (T.D. 9187, 2005–13 I.R.B. 778) that disallow certain losses recognized on sales of subsidiary stock by members of a consolidated group.