The court rejected this argument, stating the statute's language limits the amount of indebtedness
on the home or homes, not the amount of a taxpayer's indebtedness
Because home equity indebtedness
is defined in Sec.
Qualified residence interest is interest on acquisition indebtedness
or home equity indebtedness
with respect to a taxpayer's qualified residence (in this case, there was no question that the residences involved were qualified residences).
Harman exchanged an additional $2,400,000 of indebtedness
for additional shares of Company common stock such that Harman will own approximately 1,509,000 shares resulting in ownership of 19% of the then outstanding shares on a fully diluted basis after giving effect to the transactions described above.
In a separate amendment, the RRA expanded the list of tax attributes that are reduced in the case of discharge of indebtedness
to include minimum tax credits and passive activity loss and credit carryovers.
When the indebtedness
is issued for cash, which is not treated as property, the issue price is considered to be the cash amount borrowed; OID results if the amount to be paid (other than interest payable currently) exceeds the cash borrowed.
Anchor announced that it is also exploring other alternatives, which may include a restructuring of its indebtedness
and that, in that connection, a special committee of its independent directors had been formed to guide a possible restructuring.
108(b) or (g) (dealing with tax attributes and qualified farm indebtedness
The special treatment pertaining to the discharge of qualified real estate indebtedness
allows some relief for those individuals whose real estate investments have gone sour.
The notes will rank junior in right of payment with all of the Company's existing and future senior indebtedness
and equal in right of payment with any of its other senior subordinated indebtedness
The amount must be computed as a percentage of the stated principal amount of the indebtedness
incurred by the taxpayer.
Mixed recourse and nonrecourse indebtedness
6 million in aggregate principal outstanding indebtedness
") of IMPSAT Argentina and IMPSAT Brazil pursuant to separate credit agreements that are each guaranteed by IMPSAT.
61(a)(12), a taxpayer generally must include as gross income any income derived from discharge of indebtedness
After giving effect to all principal repayments in the fourth quarter of 2005, GCA estimates that its total indebtedness