Right of Subrogation. With respect to a payment made by a taxpayer in discharge of part or all of the tax- payer’s agreement to act as a guar- antor, endorser, or indemnitor where the agreement provides for a right of subrogation or other similar right against the issuer, treatment as a worthless debt is not allowed until the taxable year in which the right of sub- rogation or other similar right be- comes totally worthless (or partially worthless in the case of an agreement which arose in the course of the tax- payer’s trade or business).
Appears in 4 contracts
Sources: Taxpayer Agreement, Tax Treatment Agreement, Tax Agreement