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INCOME TAX

Internal Revenue Bulletin 2010-45 · 2026-10-03 edition · updated 2026-10-04 · United States

T.D. 9498, page 605. REG–144762–09, page 637. Temporary and proposed regulations under section 108 of the Code provide rules regarding partnerships and S corporations. Section 108(i) allows a taxpayer to defer discharge of indebtedness income (and in certain cases, deductions for original issue discount) arising from a reacquisition of an applicable debt instrument that occurs in 2009 or 2010 for a four or five taxable-year period (unless an acceleration event occurs earlier). Once the deferral period ends, taxpayers take into account the deferred income and deductions ratably over a five taxable-year period.

T.D. 9499, page 622. Final regulations under section 6411 of the Code amend existing regulations relating to the computation and allowance of the tentative carryback adjustments.

REG–119921–09, page 626. Proposed regulations under section 7701 of the Code provide whether or not a series of a domestic series LLC, a cell of a

Finding Lists begin on page ii.

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