Ezel / IRS Rulings / 200919048

CCA 200919048: Foreclosure date fixed the debt-discharge date

Number
200919048
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Qualified Principal Residence Indebtedness
Topics
Income and deductions
Code sections
§ 108
Ruling dated
December 18, 2008
Publicly released
May 8, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel answered a cancellation-of-debt question concerning qualified principal residence indebtedness. The substantive details of the question were redacted from the public release. The advice states only that the date of discharge is the date of foreclosure.

Ruling snapshot

  • Question: On what date did the debt discharge occur in the redacted foreclosure matter?
  • Outcome: Advice given: the discharge date was the foreclosure date.
  • Key authorities: IRC § 108 (identified by the document's UILC classification).

Full text (IRS public release)

ID: CCA-121801-08 Number: 200919048
Release Date: 5/8/2009
Office: ----------------
UILC: 108.01-03

From: ----------------------
Sent: December 18, 2008
To: ---------------
Cc:
Subject: COD question

-------
To confirm our earlier conversation, the answer to your Question A is the date of discharge is the date of
foreclosure ---------.

Thank you.
---------------------
-------------------

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