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2026-07-06 10:51:44 -04:00

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LegalText 26 U.S.C. § 1282 Deferral of interest deduction allocable to accrued discount us united_states_code code_section 26 INTERNAL REVENUE CODE 1 NORMAL TAXES AND SURTAXES 1282 26 U.S.C. § 1282 current 119-100 2026-06-26 official https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip /us/usc/t26/s1282 data/legal/raw/us/code/title-26/usc26.xml 4334466ebf61df9e851567a085ec1e62e690d082574fee110e804ac024a0a658 a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4 b0f4133381fbda1f6fc2687c6f2daa38a1d6a22d2617da6d30a9f96512d8d69d 2026-07-04 official
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26 U.S.C. § 1282 - Deferral of interest deduction allocable to accrued discount

Text

(a) General rule Except as otherwise provided in this section, the net direct interest expense with respect to any short-term obligation shall be allowed as a deduction for the taxable year only to the extent such expense exceeds the sum of—

(1) the daily portions of the acquisition discount for each day during the taxable year on which the taxpayer held such obligation, and

(2) the amount of any interest payable on the obligation (other than interest taken into account in determining the amount of the acquisition discount) which accrues during the taxable year while the taxpayer held such obligation (and is not included in the gross income of the taxpayer for such taxable year by reason of the taxpayers method of accounting).

(b) Section not to apply to obligations to which section 1281 applies (1) In general This section shall not apply to any short-term obligation to which section 1281 applies.

(2) Election to have section 1281 apply to all obligations (A) In general A taxpayer may make an election under this paragraph to have section 1281 apply to all short-term obligations acquired by the taxpayer on or after the 1st day of the 1st taxable year to which such election applies.

(B) Period to which election applies An election under this paragraph shall apply to the taxable year for which it is made and for all subsequent taxable years, unless the taxpayer secures the consent of the Secretary to the revocation of such election.

(c) Certain rules made applicable Rules similar to the rules of subsections (b) and (c) of section 1277 shall apply for purposes of this section.

(d) Cross reference For special rules limiting the application of this section to original issue discount in the case of nongovernmental obligations, see section 1283(c).

(Added Pub. L. 98369, div. A, title I, § 41(a), July 18, 1984, 98 Stat. 549; amended Pub. L. 99514, title XVIII, § 1803(a)(8)(B), Oct. 22, 1986, 100 Stat. 2794.)

Notes

Editorial Notes

Amendments1986—Subsec. (a). Pub. L. 99514 amended subsec. (a) generally, designating existing provisions as par. (1) and adding par. (2).

Statutory Notes and Related Subsidiaries

Effective Date of 1986 AmendmentAmendment by Pub. L. 99514 effective, except as otherwise provided, as if included in the provisions of the Tax Reform Act of 1984, Pub. L. 98369, div. A, to which such amendment relates, see section 1881 of Pub. L. 99514, set out as a note under section 48 of this title.

Effective DateSection applicable to taxable years ending after July 18, 1984, and to obligations acquired after that date, see section 44 of Pub. L. 98369, set out as a note under section 1271 of this title.

Plan Amendments Not Required Until January 1, 1989For provisions directing that if any amendments made by subtitle A or subtitle C of title XI [§§ 11011147 and 11711177] or title XVIII [§§ 18001899A] of Pub. L. 99514 require an amendment to any plan, such plan amendment shall not be required to be made before the first plan year beginning on or after Jan. 1, 1989, see section 1140 of Pub. L. 99514, as amended, set out as a note under section 401 of this title.