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Taxpayers who have taken a position contrary to the Supreme Court's decision may have an opportunity for a refund for open years for those who file a refund claim based on the case.

However, the Treasury Department may recommend legislation to close such a windfall; whether or not the legislation would be retroactive is uncertain.

In effect, cancellation of debt income realized by an insolvent S corporation and excluded under Internal Revenue Code Section 108(a) will be treated as a tax-exempt income item that flows through to the S corporation's shareholders and will increase the shareholders' bases.

Thus, the shareholder avoids income from cancellation of a debt, while increasing his basis in his S corporation stock, resulting in a potential loss upon the liquidation or sale of the S corporation.

However, IRC Section 108(a) provides an exception to the general rule in that COD income can be excluded from gross income if the discharge occurs when the taxpayer is bankrupt or insolvent.

If COD income is excluded using the insolvency exception, IRC Section 108(b) generally requires a reduction in the taxpayer's tax attributes, including net operating losses, various credits, and basis reductions that would be used to offset future taxable income.

Instead of just excluding the COD income, Gitlitz treated the excluded COD income as an income item and increased his basis in his PDW&A stock by

Taxpayers who have taken a position contrary to the Supreme Court's decision may have an opportunity for a refund for open years for those who file a refund claim based on the case.However, the Treasury Department may recommend legislation to close such a windfall; whether or not the legislation would be retroactive is uncertain.In effect, cancellation of debt income realized by an insolvent S corporation and excluded under Internal Revenue Code Section 108(a) will be treated as a tax-exempt income item that flows through to the S corporation's shareholders and will increase the shareholders' bases.Thus, the shareholder avoids income from cancellation of a debt, while increasing his basis in his S corporation stock, resulting in a potential loss upon the liquidation or sale of the S corporation.However, IRC Section 108(a) provides an exception to the general rule in that COD income can be excluded from gross income if the discharge occurs when the taxpayer is bankrupt or insolvent.If COD income is excluded using the insolvency exception, IRC Section 108(b) generally requires a reduction in the taxpayer's tax attributes, including net operating losses, various credits, and basis reductions that would be used to offset future taxable income.Instead of just excluding the COD income, Gitlitz treated the excluded COD income as an income item and increased his basis in his PDW&A stock by $1 million. Court of Appeals for the 10th Circuit affirmed the commissioner's decision by rejecting the taxpayer's position that the excluded COD income did not increase the shareholder's stock basis.Additionally, Gitlitz claimed a loss of $1 million on his 1991 federal income-tax return due to prior S corporation losses for which he had no basis in his stock. The Supreme Court decided to take the case due to split decisions among the various circuits. First, the court considered whether the IRC permits taxpayers to increase bases in their S corporation stock by the amount of an S corporation's COD income excluded from gross income.

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Taxpayers who have taken a position contrary to the Supreme Court's decision may have an opportunity for a refund for open years for those who file a refund claim based on the case.

However, the Treasury Department may recommend legislation to close such a windfall; whether or not the legislation would be retroactive is uncertain.

In effect, cancellation of debt income realized by an insolvent S corporation and excluded under Internal Revenue Code Section 108(a) will be treated as a tax-exempt income item that flows through to the S corporation's shareholders and will increase the shareholders' bases.

Thus, the shareholder avoids income from cancellation of a debt, while increasing his basis in his S corporation stock, resulting in a potential loss upon the liquidation or sale of the S corporation.

However, IRC Section 108(a) provides an exception to the general rule in that COD income can be excluded from gross income if the discharge occurs when the taxpayer is bankrupt or insolvent.

If COD income is excluded using the insolvency exception, IRC Section 108(b) generally requires a reduction in the taxpayer's tax attributes, including net operating losses, various credits, and basis reductions that would be used to offset future taxable income.

Instead of just excluding the COD income, Gitlitz treated the excluded COD income as an income item and increased his basis in his PDW&A stock by $1 million. Court of Appeals for the 10th Circuit affirmed the commissioner's decision by rejecting the taxpayer's position that the excluded COD income did not increase the shareholder's stock basis.

million. Court of Appeals for the 10th Circuit affirmed the commissioner's decision by rejecting the taxpayer's position that the excluded COD income did not increase the shareholder's stock basis.

At the time of liquidation, you get the land in trade for your stock.Additionally, the Supreme Court ruled that the flow through of COD income occurs before the reduction of the S corporation's tax attributes under IRC Section 108(b).It appears that such income should be reported the same way tax-exempt income is reported on Schedules K and K-1 of the S corporation's tax return. Many small companies, including real estate-related ventures, elect to be treated as S corporations with the Internal Revenue Service. Supreme Court recently ruled in favor of taxpayers in a potential windfall decision for shareholders of S corporations.




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