Debt Collateralized by Interest in Ownership Entity Will Be Deemed To Be Secured by Real Property

摘要

Debt collateralized by an interest in an entity owning real property will be deemed to be secured by real prop-rnerty for purposes of the cancellation of indebtedness provisions of Section 108 of the Internal Revenue Code, according to an Internal Revenue Service private letter ruling. (PLR 200953005, 2009 WL 5166564 (IRS PLR), issued September 23, 2009, and released December 31, 2009).