not have been brought against the tax- payer); andTaxpayer Agreement • January 20th, 2024
Contract Type FiledJanuary 20th, 2024§§ 1.166–2 and 1.166–3 for rules on worth- less and partially worthless debts. For purposes 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.