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TOPICS / TAX

When does debt become worthless?

The Ninth Circuit, affirming the Tax Court, recently held that to deduct a nonbusiness bad debt, the debt must be “wholly worthless,” and if the debtor reports cancellation-of-debt (COD) income, the discharged debt is not thereby presumed to be worthless to the creditor. Facts: From 2007 to 2010, Michael R.

Tax Court denies $23 million façade easement deduction

The Tax Court denied a limited liability company’s (LLC’s) claimed charitable conservation contribution deduction under Sec. 170(h) for its donation of a façade easement because the LLC failed to establish that the building was a “certified historic structure” under Sec. 170(h)(4)(C). The court also rejected the LLC’s argument that the

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