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2004-33 provides automatic consent procedures for taxpayers to change their method of accounting and treat these credit card late fees as interest that creates or increases the amount of original issue discount on a pool of credit card loans to which the fees relate. A discount can either be an original issue discount ( Section 7872 generally provides that a below-market interest rate loan has an original issue discount (OLD) equal to the present value difference between the discounted loan payments, and imputed payments at the applicable federal rate. |
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