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Internal Revenue Service Exculpatory Clauses

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Goulston & Storrs PC

IRS Ruling Addresses LLC Eligibility for Cancellation of Debt Exception

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In new CCA 201525010, the IRS addressed the issue of whether a general “exculpatory” debt of an LLC is recourse or non-recourse for purposes of classifying debt-relief as potential cancellation of debt (COD) income. Recourse...more

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