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Section 1367 Regarding Open Account Debt; Correction

---
identifier: "/us/fr/E8-27024"
source: "fr"
legal_status: "authoritative_unofficial"
title: "Section 1367 Regarding Open Account Debt; Correction"
title_number: 0
title_name: "Federal Register"
section_number: "E8-27024"
section_name: "Section 1367 Regarding Open Account Debt; Correction"
positive_law: false
currency: "2008-11-14"
last_updated: "2008-11-14"
format_version: "1.1.0"
generator: "[email protected]"
agency: "Treasury Department"
document_number: "E8-27024"
document_type: "rule"
publication_date: "2008-11-14"
agencies:
  - "Treasury Department"
  - "Internal Revenue Service"
cfr_references:
  - "26 CFR Part 1"
rin: "1545-BD72"
fr_citation: "73 FR 67388"
fr_volume: 73
docket_ids:
  - "TD 9428"
effective_date: "2008-11-14"
fr_action: "Correcting amendment."
---

#  Adjustments to basis of indebtedness to shareholder.

**AGENCY:**

Internal Revenue Service (IRS), Treasury.

**ACTION:**

Correcting amendment.

**SUMMARY:**

This document contains corrections to final regulations (TD 9428) that were published in the *Federal Register* on Monday, October 20, 2008 (73 FR62199) relating to the treatment of open account debt between S corporations and their shareholders. These final regulations provide rules regarding the definition of open account debt and the adjustments in basis of any indebtedness of an S corporation to a shareholder under section 1367(b)(2) of the Internal Revenue Code for shareholder advances and repayments on advances of open account debt. The regulations affect shareholders of S corporations and are necessary to provide guidance needed to comply with the applicable tax law.

**DATES:**

*Effective Date:* This correction is effective November 14, 2008, and is applicable on October 20, 2008.

**FOR FURTHER INFORMATION CONTACT:**

Stacy L. Short or Deane M. Burke, (202) 622-3070 (not a toll-free number).

**SUPPLEMENTARY INFORMATION:**

**Background**

The final regulations that are the subjects of this document are under section 1367 of the Internal Revenue Code.

**Need for Correction**

As published, final regulations (TD 9428) contain errors that may prove to be misleading and are in need of clarification.

**List of Subjects in 26 CFR Part 1**

Income taxes, Reporting and recordkeeping requirements.

**26 CFR Part 1**

**Correction of Publication**

Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:

**PART 1—INCOME TAXES**

*Paragraph 1.* The authority citation for part 1 continues to read, in part, as follows:

**Authority:**

26 U.S.C. 7805 * * *

**26 CFR Part 1**

*Par. 2.* Section 1.1367-2(e) is amended by revising the title of paragraph *Example 6.*

and the first sentence of paragraph *Example 7.* (i) to read as follows:

§ 1.1367-2

(e) * * *

*Example 6. The $25,000 aggregate principal amount applies to each shareholder.* * * *

*Example 7.* * * *

(i) The facts are the same as in *Example 6,* in addition to which, on December 31, 2009, A's basis in the open account debt is reduced under paragraph (b) of this section to $8,000. * * *

LaNita Van Dyke,

Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration).