I 

117TH CONGRESS 

1ST SESSION H. R. 2077 

To amend the Internal Revenue Code of 1986 to exclude discharges of 

indebtedness on taxi medallions from gross income. 

IN THE HOUSE OF REPRESENTATIVES 

MARCH 19, 2021 

Mr. MEEKS (for himself, Mrs. CAROLYN B. MALONEY of New York, Mr. 

SUOZZI, Ms. VELA ́ZQUEZ, Miss RICE of New York, Mr. ESPAILLAT, Ms. 

OCASIO-CORTEZ, Mr. NADLER, Mr. TORRES of New York, Ms. CLARKE

of New York, Ms. MENG, Mr. JEFFRIES, Ms. MALLIOTAKIS, and Mr. 

BOWMAN) introduced the following bill; which was referred to the Committee on Ways and Means 

A BILL 

To amend the Internal Revenue Code of 1986 to exclude 

discharges of indebtedness on taxi medallions from gross 

income. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘Taxi Medallion Loan 

5 Forgiveness Debt Relief Act of 2021’’. 


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1 SEC. 2. EXCLUSION OF DISCHARGES OF QUALIFIED TAXI 

2 MEDALLION INDEBTEDNESS. 

3 (a) IN GENERAL.—Section 108(a)(1) of the Internal 

4 Revenue Code of 1986 is amended by striking ‘‘or’’ at the 

5 end of subparagraph (D), by striking the period at the 

6 end of subparagraph (E) and inserting ‘‘, or’’, and by in7 serting after subparagraph (E) the following new subpara8 graph: 

9 ‘‘(F) in the case of a taxpayer other than 

10 a C corporation, the indebtedness discharged is 

11 qualified taxi medallion indebtedness which is 

12 discharged before January 1, 2023.’’. 

13 (b) SPECIAL RULES RELATING TO QUALIFIED TAXI

14 MEDALLION INDEBTEDNESS.—Section 108 of such Code 

15 is amended by adding at the end the following new sub16 section: 

17 ‘‘(j) SPECIAL RULES RELATING TO QUALIFIED TAXI

18 MEDALLION INDEBTEDNESS.— 

19 ‘‘(1) BASIS REDUCTION.—The amount excluded 

20 from gross income by reason of subsection (a)(1)(E) 

21 shall be applied to reduce (but not below zero) the 

22 basis of the taxi medallions of the taxpayer that se23 cure the discharged indebtedness. 

24 ‘‘(2) QUALIFIED TAXI MEDALLION INDEBTED25 NESS.—For purposes of this section— 


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1 ‘‘(A) IN GENERAL.—The term ‘qualified 

2 taxi medallion indebtedness’ means indebted3 ness which— 

4 ‘‘(i) is secured by a taxi medallion, 

5 and 

6 ‘‘(ii) with respect to which such tax7 payer makes an election to have this para8 graph apply. 

9 ‘‘(B) LIMITATION.—With respect to a tax10 payer, the aggregate amount treated as quali11 fied taxi medallion indebtedness for any period 

12 shall not exceed $2,000,000 ($1,000,000 in the 

13 case of a married individual filing a separate re14 turn). 

15 ‘‘(C) EXCEPTION FOR CERTAIN DIS16 CHARGES NOT RELATED TO TAXPAYER’S FINAN17 CIAL CONDITION.—Subsection (a)(1)(F) shall 

18 not apply to the discharge of a loan if the dis19 charge is on account of services performed for 

20 the lender or any other factor not directly re21 lated to a decline in the value of the taxi medal22 lion or to the financial condition of the tax23 payer. 

24 ‘‘(D) ORDERING RULE.—If any loan is dis25 charged, in whole or in part, and only a portion 


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1 of such loan is qualified taxi medallion indebt2 edness, subsection (a)(1)(F) shall apply only to 

3 so much of the amount discharged as exceeds 

4 the amount of the loan (as determined imme5 diately before such discharge) which is not 

6 qualified taxi medallion indebtedness.’’. 

7 (c) CONFORMING AMENDMENTS.— 

8 (1) Section 108(a)(2) of such Code is amended 

9 by adding at the end the following new subpara10 graph: 

11 ‘‘(D) TAXI MEDALLION EXCLUSION TAKES

12 PRECEDENCE OVER INSOLVENCY EXCLUSION

13 UNLESS ELECTED OTHERWISE.—Paragraph 

14 (1)(B) shall not apply to a discharge to which 

15 paragraph (1)(F) applies unless the taxpayer 

16 elects to apply paragraph (1)(B) in lieu of para17 graph (1)(F).’’. 

18 (d) EFFECTIVE DATE.—The amendments made by 

19 this section shall apply to discharges of indebtedness after 

20 December 31, 2016. 

Æ 


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