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" ... Because A and B are insolvent, however, they may avail themselves of Section 108(a)(1)(B) to the extent of their insolvency. Assuming both individuals are insolvent by more than $25,000, they are permitted to exclude the $25,000 of COD from their taxable income, though they must then reduce certain tax attributes, such as net operating losses, capital loss carryfowards, etc... ... "