Section 7872 recharacterizes a
below-market loan as a market rate loan and an additional transfer
by the lender to the borrower equal to the amount of imputed
interest. The regulation requires both the lender and the borrower
to attach a statement to their respective income tax returns for
years in which they have either imputed income or claim imputed
deductions under section 7872.
US Code:
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USC 7872 Name of Law: Treatment of loans with below-market
interest rates
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