Modifications of Bad Debts and Dealer Assignments of Notional Principal Contracts

This document contains regulations that deem a charge-off and allow a deduction for a partially worthless debt when the terms of a debt instrument have been modified. The regulations provide guidance to certain taxpayers that have claimed a deduction for a partially worthless debt and then modified the terms of the debt instrument. This document also contains regulations relating to certain assignments of notional principal contracts by dealers in those contracts. The regulations provide guidance to taxpayers relating to the consequences of these assignments.