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    Document / Legal Opinion

    IRS General Information Letter (Swaps)

    Posted 2017
    Author
    Karin G. Gross
    About This Legal Opinion

    Therefore, except in the very limited situations of a swap that meets the extinguishment requirements of section 1.170A-14(g)(6) of the Regulations, the contribution of an easement made subject to a swap is not deductible under section 170(h) of the Code.

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