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In Notice 2005-70, IRS provides interim guidance on how to make a Section 362(e)(2)(C) election pending the issuance of further additional guidance.
Section 362(e) was enacted as part of the "American Jobs Creation Act of 2004." It generally provides if property is transferred to a corporation as a capital contribution or in a section 351 exchange, and the aggregate basis of the property exceeds its aggregate value immediately after the transaction, then the transferee corporation's basis in the property can't exceed the property's fair market value.
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