Internal Revenue Service, Treasury § 1.166–10Tax Treatment Agreement • February 16th, 2022
Contract Type FiledFebruary 16th, 2022purposes of this paragraph (d)(3), an agreement is considered as entered into before the obligation became worthless (or partially worthless) if there was a reasonable expectation on the part of the taxpayer at the time the agree- ment was entered into that the tax- payer would not be called upon to pay the debt (subject to such agreement) without full reimbursement from the issuer of the obligation.