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OVERVIEWCOD INCOME TAX ATTRIBUTES AND INSOLVENCY
AMOUNT OF COD INCOME
MODIFICATIONS OF OUTSTANDING DEBT
9 other sections not shown
5-percent shareholder acquisition adjusted issue price allocable apply Bankr Bankruptcy Code bankruptcy court bankruptcy estate Bankruptcy Exception basis beneficial owners built-in gain built-in loss cancellation carryback carryforwards carryovers cash change date Chapter 11 claims COD income consolidated group Debt Exception debt instrument debtor deduction deemed exchange determined discount entity ERISA example face amount fair market value federal exemption filing fund indebtedness insolvent interest Internal Revenue Code Internal Revenue Service investment unit issuance issuer liability liquidation preference loss corporation NOLs nominal or token nonrecourse debt old debt ownership change occurs parent payments pension plan percent principal amount private letter ruling Prop proposed regulations provides publicly traded purposes Ratio recapitalization redemption price restructuring result section 382 limitation Service spendthrift trust stock-for-debt exception subsidiary tax attributes taxable taxpayer Temp testing date title 11 transaction transfer Treas treated unrealized built-in unsecured creditors