Taxpayer election Sample Clauses

Taxpayer election. (1) In general. (2) Limitation not applicable. (3) Time and manner of election. (4) Example.
Taxpayer election. (1) In general. An interest holder (or individual treat- ed as an interest holder) may elect to treat as a taxable event the payment of an unpaid qualified payment occurring more than four years after its due date. Under this election, the increase under paragraph (c) of this section is deter- mined only with respect to that pay- ment and all previous payments for which an election was available but not made. Payments for which an election applies are treated as having been paid on their due dates for purposes of sub- sequent taxable events. The election is revocable only with the consent of the Commissioner.