Irc 197 intangibles. (a) Overview -- (1) In general.

Irc 197 intangibles. A pragmatic approach to amortization of intangibles. A taxpayer shall be entitled to an amortization deduction with respect to any amortizable section 197 [26 USCS § 197] intangible. Mar 15, 2010 · Under new IRC Sec. Relevant Tax Codes and Regulations: IRC Section 197 governs the amortization of specific intangible assets over a 15-year period. (a) General rule A taxpayer shall be entitled to an amortization deduction with respect to any amortizable section 197 intangible. (b) No other depreciation or § 1. Charitable, etc. The following rules and definitions provide guidance concerning property that is a section 197 intangible unless an exception applies: (1) Goodwill. C. Sep 1, 2018 · However, the Internal Revenue Code is rigid on the position that for income tax purposes under Sec. Try refreshing the page Contact CCH Support Call CCH Support at 1-800-344-3734 Back to Original Document 26 USC 197: Amortization of goodwill and certain other intangiblesText contains those laws in effect on January 3, 2016 From Title 26-INTERNAL REVENUE CODESubtitle A-Income TaxesCHAPTER 1-NORMAL TAXES AND SURTAXESSubchapter B-Computation of Taxable IncomePART VI-ITEMIZED DEDUCTIONS FOR INDIVIDUALS AND CORPORATIONS Jump To: Source Credit References In Text Amendments if section 197 applies and over 36 months if the software is not a section 197 intangible. Amortization of goodwill and certain other intangibles. In addition, setting of separate and distinct values for goodwill against other intangible 2023 U. Recovery petitioned the Tax Court. Can you then write off the goodwill on your tax return and take the deduction? In order to address this puzzling question, let's first review the relevant portions of Internal Revenue Code Sec. Other assets, such as patents and copyrights, are amortizable under IRC section 197 if they are purchased as part of a trade or business. §197. The rules for determining whether such basis adjustments are subject to the anti-churning rules under section 197(f)(9) operate by reference to the facts surrounding each partner’s acquisition of its Jan 21, 2025 · Now, when we talk about Section 197 intangibles, we’re referring to a specific group of these intangible assets that need to be treated in a certain way for tax purposes. Taxpayers tangibles are a § 197 intangible. Feb 7, 2025 · Overview of Intangible Amortization From a tax perspective, intangible assets are generally those assets without a physical form that can provide a long-term benefit to a business. A trap for the unwary The anti-churning rules under Sec. Jun 28, 2025 · When a buyer acquires a business, any amount paid for a covenant not to compete is considered the purchase of a specific type of intangible asset. 1954]. For purposes of this chapter, any amortiz-able section 197 intangible shall be treated as property which is of a character subject to the allowance for depreciation provided in section 167. Any other information with respect to other assets transferred in such acquisition as the Secretary deems necessary to carry out the provisions of this section. Aug 17, 2025 · Understand the tax treatment and recovery period for Section 197 intangible assets. Amortization of goodwill and certain other intangibles General rule. Any modification of the amount described in paragraph (1). Question: Which of the following is not correct with regard to IRC 197 intangibles? Amortization is subject to recapture as IRC 1245 property upon a taxable disposition. The amount of such deduction shall be determined by amortizing the adjusted basis (for purposes of determining gain) of such intangible ratably over the 15-year period beginning with the month in which such intangible was acquired. 197-1T has been made. Use Form 4563 to report annual amortization. 197-2, which provides the detailed rules for the tax amortization of intangibles in business acquisitions. Jan 25, 2000 · The IRS has published final regulations (T. The new law represents a substantial change from the prior law, under which neither good will nor going-concern value, two examples of IRC Sec. ISSUE If, pursuant to § 1. Mar 3, 2017 · Many of the entities that Holding and Pship 2 acquired were classified as partnerships for federal income tax purposes. Abstract- The new IRC Sec. Jun 20, 2025 · Section 197 Intangibles Section 197 of the Internal Revenue Code provides rules for certain acquired intangible assets, typically those obtained when purchasing a business. It is governed by a different Section of the IRC and methods are unique to the intangible asset based on the IRC code section relevant to various intangible. In some cases, these partnerships were formed before August 10, 1993, and, thus, goodwill and intangible assets of these entities were subject to the anti-churning rules under § 197(f)(9) of the Internal Revenue Code. Jun 22, 2025 · Qualifying Intangible Assets The Internal Revenue Code (IRC) provides specific guidance on which intangible assets qualify for amortization, primarily under Section 197. You must generally amortize over 15 years the capitalized costs of "section 197 intangibles" you acquired after August 10, 1993. This allows businesses to reduce taxable income by deducting the amortized amount, contrasting with financial accounting rules that prohibit amortization. Mar 13, 2025 · Section 197 Scope Under IRC Section 197, goodwill is classified as an amortizable intangible asset when acquired in connection with a trade or business. 101–508, set out as a note under section 45K of this title. The content might no longer be available. This includes deemed asset purchases via an Internal Revenue Code Section 338 (h) (10) election. 26 USC 197: Amortization of goodwill and certain other intangiblesText contains those laws in effect on January 3, 2024 From Title 26-INTERNAL REVENUE CODESubtitle A-Income TaxesCHAPTER 1-NORMAL TAXES AND SURTAXESSubchapter B-Computation of Taxable IncomePART VI-ITEMIZED DEDUCTIONS FOR INDIVIDUALS AND CORPORATIONS Jump To: Source Credit Miscellaneous References In Text Amendments Effective Date Sep 1, 2009 · Application of the Antichurning Rules to an Asset Sale In contrast to the above discussion of the effects that Regs. Summary (a) General rule. Jan 16, 1997 · The IRS has published proposed regulations (REG-209709-94) on the amortization of intangible assets under sections 167 (f) and 197. 197] intangibles. The amount of such deduction shall be determined by amortizing the adjusted basis (for purposes of determining gain) of such intangible ratably over the 15-year period beginning with the month in which such LII Electronic Code of Federal Regulations (e-CFR) Title 26—Internal Revenue CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY SUBCHAPTER A—INCOME TAX PART 1—INCOME TAXES Tax on Corporations § 1. Amortization of pollution control facilities § 170. If a taxpayer disposes of more than 1 amortizable section 197 intangible (as defined in section 197 (c)) in a transaction or a series of related transactions, all such amortizable 197 intangibles shall be treated as 1 section 1245 property for purposes of this section. Part II covers the income- forecast and units-of-production methods, computer software, transaction costs and Sec. Section 197 [26 USCS § 197] allows an amortization deduction for the capitalized costs of an amortizable section 197 [26 USCS § 197] intangible and prohibits any other depreciation or amortization with respect to that property. Accelerated cost recovery system § 169. Code Title 26 - Internal Revenue Code Subtitle A - Income Taxes Chapter 1 - Normal Taxes and Surtaxes Subchapter B - Computation of Taxable Income Part VI - Itemized Deductions for Individuals and Corporations Sec. A taxpayer generally may claim an amortization deduction under IRC §197 for the capital costs of an amortizable section 197 intangible, by ratably amortizing the intangible’s adjusted basis over the 15-year period beginning with the month in which the taxpayer acquired the intangible. For tangible property, the key date is 1987; assets in service before then fall under older systems. Jul 25, 2019 · 26 USC 197: Amortization of goodwill and certain other intangiblesText contains those laws in effect on October 12, 2025 From Title 26-INTERNAL REVENUE CODESubtitle A-Income TaxesCHAPTER 1-NORMAL TAXES AND SURTAXESSubchapter B-Computation of Taxable IncomePART VI-ITEMIZED DEDUCTIONS FOR INDIVIDUALS AND CORPORATIONS Jump To: Source Credit Miscellaneous References In Text Amendments Effective Date Aug 8, 2005 · Section 197 intangibles are certain intangible assets acquired after August 10, 1993 (or after July 25, 1991, if chosen) in connection with the acquisition of a business which must be amortized over 15 years from the date of acquisition regardless of the assets useful life. Jan 17, 2017 · Preface: Amortization of intangible assets is similar yet different than depreciation. 197, a taxpayer must amortize acquired intangible assets on a straight-line basis over a 15-year period, regardless of any changes in the value or useful life asserted by the taxpayer or disclosed in its financial statements, unless there is a Thus, in regards to intangible property consider property such as the goodwill from a business, which would be considered intangible property, or certain intellectual property rights such as a copyright or patent could be considered intangible property. (3) Amounts otherwise deductible. Of particular relevance to the sports investment community is a targeted revision to Internal Revenue Code (IRC) Section 197, which governs the amortization of intangible Sep 19, 2023 · Internal Revenue Code Section 197 allows for cost recovery of expenses related to certain intangible assets. L. 10, 1993. Interest § 164. May 1, 2018 · Section 197 governs amortization deductions for many types of intangible assets. There could be a communication or technical problem. When a taxpayer disposes of certain section 197 intangibles, special rules may apply if— a controlled group is disposing a section 197 intangible. Depreciation § 168. Identifying a Related Party Title: Unknown : Author: amontero : Created Date: 11/12/2001 5:17:40 PM It establishes a mandatory 15-year recovery period for assets such as goodwill, trademarks, franchises, licenses granted by governmental agencies, and customer-based intangibles. ”5 While the list of amortizable Section 197 intangibles is broad, it is a list assembled in the early 1990s. A key feature is their amortization schedule; the cost must be amortized over a 15-year period, beginning in the month the asset is acquired. Allowance of deductions § 162. D. The cost of certain intangible assets can be recovered using the units-of Apr 1, 2024 · See Code Section 197—determining tax treatment amortization of goodwill and certain other intangibles. Recovery amortized the covenant over its life of 12 months. , to be amortized ratably over 15 years. The IRS determined that the covenant was an IRC § 197 intangible and therefore amortizable by Recovery over 15 years. 197-2 and 1. This section, enacted as part of the Omnibus Budget Reconciliation Act of 1993, standardizes the treatment of intangible assets, including trademarks, customer lists, and licenses. The amount of such deduction shall be determined by amortizing the adjusted basis (for purposes of determining gain) of such intangible ratably over the 15-year period beginning with the month in which such Section 197 was enacted to reduce controversy between taxpayers and the IRS in connection with the amortization of certain intangible assets, including goodwill and going concern value. Amortization of goodwill and certain other intangibles § 161. (B) Exception. (3) Workforce in place. (8) Licenses, permits, and See sections 197 and 167 (f) and, to the extent applicable, §§ 1. Overview—(1) In general. For Section 197 intangibles, the period is between July 25, 1991, and August 10, 1993. May 1, 2007 · This two-part article provides an overview of cost recovery for intangible asset expenditures. See Explanation: §197 (a) for more details on this general rule. For tax purposes, this asset falls under the category of “Section 197 intangibles. 197-2(f)(4)(i) Amortization of goodwill and certain other intangibles. General rule. 167 (a)-14 Treatment of certain intangible property excluded from section 197. Except as otherwise provided in paragraph (c) of this section, the term section 197 intangible means any property described in section 197 (d) (1). These assets, known as “Section 197 intangibles,” are acquired as part of purchasing an entire business or a substantial portion of one. May 1, 2021 · A was the only individual partner in partnership W. §197 TITLE 26—INTERNAL REVENUE CODE Page 924 [enacting this section and amending sections 48, 312, and 1016 of this title] shall apply to periods after De-cember 31, 1982, under rules similar to the rules of sec-tion 48(m) of the Internal Revenue Code of 1986 [for-merly I. Jan 3, 2022 · Explore the problem of transferring zero-basis intangibles to a foreign partnership and the IRS' response. I. (a) Overview — (1) In general. (5) Know-how, etc. This blog is provide an explanation of amortization and namely IRC Code Section 197 relevant to the majority of small business intangible assets May 23, 2025 · The recently proposed “Big, Beautiful Bill” (BBB), currently under preliminary markup in the Senate Finance Committee, includes a suite of tax provisions aimed at deficit reduction, corporate reform and base-broadening. The amount of such deduction shall be determined by amortizing the adjusted basis (for purposes of determining gain) of such intangible ratably over the 15-year period beginning with the month in which such This is in reply to your letter of January 11, 2002, and additional correspondence dated March 6, 2002, and June 6, 2002, requesting a ruling on the proper treatment of goodwill and going concern value under §§ 197 and 1221 of the Internal Revenue Code. Part I summarizes the applicable capitalization regulations, Sec. 197 - Amortization of goodwill and certain other intangibles Oct 4, 2024 · Learn what Section 197 intangibles are, how to amortize them, key IRS rules, valuation challenges, and FAQs on selling, compliance, and tax treatment. Sep 18, 2024 · Section 197 intangibles are assets acquired through business purchases. (2) Going concern value. by Young, James C. The new revenue procedure does not apply to IRC section 197 intangibles. 197 intangibles”) are amortizable ratably over a 15-year period. Internal Revenue Code § 197. S. Apr 1, 2007 · This two-part article examines cost recovery of intangible asset expenditures. Losses § 166. Taxes § 165. com. Amortization of Section 197 assets is done on a straight-line basis. Section 1. 8865) on the amortization of intangible property under section 197. Common examples include: § 1. (6) Customer-based intangibles. Sec. This section provides rules for the amortization of certain intangibles that are excluded from section 197 (relating to the amortization of goodwill and certain other intangibles). Section 197(d)(2) defines the term “customer-based intangibles” as meaning (i) composition of market, (ii) market share, and (iii) any other value resulting from future provision of goods or services pursuant to relationships (contractual or otherwise) in the ordinar Tax Treatment of Intangibles IRC Sec 197 allows acquired intangibles like goodwill, going concern value, etc. Under this section, goodwill is now eligible for amortization. §197 TITLE 26—INTERNAL REVENUE CODE Page 860 previously taken into account under section 46(d) of this title, and any property described in section 46(b)(2)(C) of this title, as such sections were in effect on Nov. Jul 25, 1991 · For purposes of this chapter, any amortizable section 197 intangible shall be treated as property which is of a character subject to the allowance for depreciation provided in section 167. Aug 1, 2011 · Treating self-created customer-based intangibles as assets separate from goodwill can result in more favorable tax treatment for these intangibles. 197-2 (g) (1), loss is disallowed to the extent the intangible was acquired in the same transaction (or series of transactions) along with other section 197 intangibles that are retained. Searchable text of the 26 USC 197 - Amortization of goodwill and certain other intangibles (US Code), including Notes, Amendments, and Table of Authorities 26 USC 197: Amortization of goodwill and certain other intangiblesText contains those laws in effect on October 7, 2025 From Title 26-INTERNAL REVENUE CODESubtitle A-Income TaxesCHAPTER 1-NORMAL TAXES AND SURTAXESSubchapter B-Computation of Taxable IncomePART VI-ITEMIZED DEDUCTIONS FOR INDIVIDUALS AND CORPORATIONS Jump To: Source Credit Miscellaneous References In Text Amendments Effective Date A taxpayer shall be entitled to an amortization deduction with respect to any amortizable section 197 intangible. (7) Supplier-based intangibles. Reg. R. Common examples include trademarks, patents, goodwill, going-concern value, licenses, and noncompetition agreements. The regs adopt, with modifications, the proposed For this purpose, a bank affiliate is a corporation whose principal activity is rendering services to facilitate exchanges of property intended to qualify for nonrecognition of gain under section 1031 of the Internal Revenue Code and all of whose stock is owned by either a bank or a bank-holding company. Jun 19, 2025 · Understand the framework of Treas. A taxpayer shall be entitled to an amortization deduction with respect to any amortizable section 197 intangible. Amortization of goodwill and certain other intangibles (a) General rule A taxpayer shall be entitled to an amortization deduction with respect to any amortizable section 197 intangible. 197-2 Amortization of goodwill and certain other intangibles. 197 cost recovery and general Sec. You start amortization the month the intangible is acquired. Trade or business expenses § 163. In the case of LTP1, LTP2, LTP3, LTP4, and LTP5, the 2 days ago · (A) In general. Paragraphs (b), (c), and (e) of this sec-tion provide rules and definitions for determining whether property is a sec-tion 197 intangible, and paragraphs (d) and (e) of Aug 16, 2021 · Collapse to view only § 197. 197 was created in response to the long-standing disagreement between the IRS and taxpayers regarding the amortization of intangible assets. Get expert insights and analysis at TaxNotes. Taxpayers can, however, use two significant exceptions to remove most acquired software from the reach of this 15-year rule. 704-1(b)(2)(iv)(f) of the Income Tax Regulations, a partnership revalues a section 197 intangible, may the partnership allocate amortization with respect to the section 197 intangible so as to take into account the built-in gain or loss from the revaluation? Jan 29, 2025 · Explore IRC Section 197’s role in amortizing intangible assets like goodwill and its impact on tax strategies. 197 intangibles, were amortizable. 197, certain intangible property (defined as “IRC Sec. § 197(a) provides that a taxpayer is entitled to an amortization deduction for any amortizable § 197 intangible and the amount of such deduction is determined by amortizing the adjusted basis, for purposes of determining gain, of such intangible ratably over the 15-year period beginning with the month in which such intangible was acquired. The annual May 13, 2023 · Congress intended for Section 197 to provide “a single method and period for recovering the cost of most acquired intangible assets and by treating acquired goodwill and going concern value as amortizable intangible assets. Congress enacted section 197 in 1993 after a history of litigation between the IRS and taxpayers over the proper tax treatment of goodwill, going-concern value, and certain other intangible assets acquired in connection with the purchase of a business. (b) Safe harbor amortization for certain intangible assets — (1) Useful life. Get clarity on amortizing these business investments. CONCLUSIONS Even if the goodwill associated with the W and Y2 franchises became worthless when Manufacturer terminated the franchise agreements, section 197(f)(1) of the Internal Revenue Code1 prohibits a deduction for worthless amortizable section 197 intangibles, including goodwill, where other amortizable section 197 intangibles purchased as part of the same transaction or series of (d) Treatment of certain partnership transactions In the case of a distribution of partnership property or a transfer of an interest in a partnership— (1) the rules of subsection (a) shall apply but only for purposes of determining the value of section 197 intangibles for purposes of applying section 755, and (2) See sections 197 and 167 (f) and, to the extent applicable, §§ 1. Specifically, Taxpayer requests a ruling that the goodwill and going concern value sold under the circumstances described below are capital Sep 7, 2022 · Disposing of IRC 197 Intangibles: It’s All or Nothing In a column published in last summer’s Pennsylvania CPA Journal, we discussed why we anticipated seeing more asset deals among mergers and acquisitions as a result of certain changes brought on by the Tax Cuts and Jobs Act of 2017. The amount of the consideration received for the assets which is allocated to section 197 [IRC Sec. Bad debts § 167. (a) Overview -- (1) In general. Code - Unannotated Title 26. 2021 U. Section 197(c)(1) defines the term "amortizable section 197 intangible" to mean any section 197 intangible which is acquired by the taxpayer after the date of enactment of section 197, and which is held in connection with the conduct of a trade or business or an activity described in section 212. 167 amortization rules. The amount of such deduction shall be determined by amortizing the adjusted basis (for purposes of determining gain) of such intangible ratably over the 15-year period beginning with the month in which (11) Contracts for the use of, and term interests in, other section 197 intangibles. Acquired software that is classified as a section 197 intangible must be amortized over the significantly longer period of 15 years. All Section references are to the Internal Revenue Code of 1986, as amended, unless otherwise noted. , contributions and gifts § 171 Sep 26, 2023 · Internal Revenue Code Section 197 allows for cost recovery of expenses related to certain intangible assets. Mar 23, 2022 · The loss deferral rule: Under section 197 (f) (1) (A) and Reg. Although section 197 has largely served its purpose, the antichurning rules contained in section 197(f)(9) remain a source of much consternation for tax practitioners. undefinedRegister for a complimentary trial to unlock this document, plus gain access to so much more, including: Expert insights into the industry’s hottest topics Explanations and guidance on recent tax law changes Real-world examples and helpful practice tools §197 TITLE 26—INTERNAL REVENUE CODE Page 924 [enacting this section and amending sections 48, 312, and 1016 of this title] shall apply to periods after De-cember 31, 1982, under rules similar to the rules of sec-tion 48(m) of the Internal Revenue Code of 1986 [for-merly I. Certain intangible property is defined as a Section 197 intangible and is discussed more below. In addition, the regulations clarify that section 197 (rather than §1. Access any section from the IRC of 1986 on Tax Notes. intangible under section 734(b) is treated as a new intangible acquired as a result of the distribution. You must amortize these costs if you hold the section 197 intangibles in connection with your trade or business or in an activity engaged in for the production of income. § 197 - U. It’s generally limited to intangibles that are acquired, usually as a part of the acquisition of a business in an asset purchase transaction. 197 - Amortization of goodwill and certain other intangibles Mar 30, 2022 · What Is the Recovery Period for Section 197 Intangibles? Under Section 197, you should amortize all acquired intangible assets over 180 months, or 15 years, regardless of the asset’s useful life. To have an amortizable section 197 Reg. Paragraphs (b), (c), and (e) of this section provide rules and definitions for determining whether property is a section 197 intangible, and paragraphs (d) and (e) of See Code Section 197—determining tax treatment amortization of goodwill and certain other intangibles. 195 deductions. (a) Overview. section 1. Amortization of goodwill and certain other intangibles Current as of January 01, 2024 | Updated by FindLaw Staff undefinedThe document might not be included in your subscription or trial. This article explores the benefits, from enhanced depreciation to increased asset value, offering a comprehensive guide to maximizing returns on these critical assets. 162-11) applies to certain costs incurred with respect to leased software (that is, costs to acquire a section ntangible that is a limited inter (b) Section 197 intangibles; in general. Internal Revenue Code Section 197 simplifies the tax treatment of acquired intangible assets by establishing a uniform 15-year amortization period. An alternative possibility would apply to intangible assets acquired after July 25, 1991, which was an earlier efective date for taxpayers who elected early application of the Section 197 rules. taxpayer shall be entitled to an amortization deduction with respect to any amortizable section 197 intangible. Jan 26, 2025 · Under the Internal Revenue Code (IRC) Section 197, goodwill is classified as an intangible asset that can be amortized over 15 years for tax purposes. ” This classification is important because it dictates how the buyer can recover the cost of the payment over time. Section 197 allows an amortization deduction for the capitalized costs of an amortizable section 197 intangible and prohibits any other depreciation or amortization with respect to that property. (2) Section 167 (f) property. May 27, 2025 · Of particular relevance to the sports investment community is a targeted revision to Internal Revenue Code (IRC) Section 197, which governs the amortization of intangible assets. This article examines the rules regarding the separate treatment of self-created customer-based intangibles and the situations in which separate treatment may be beneficial. Section 197 allows an amortization deduction for the capitalized costs of an amortiz-able section 197 intangible and pro-hibits any other depreciation or amor-tization with respect to that property. 167 (a)-14 for amortization of goodwill and certain other intangibles acquired after August 10, 1993, or after July 25, 1991, if a valid retroactive election under § 1. (b) Section 197 intangibles; in general. Other relevant tax codes, such as IRC Sections 167, 195, and 248, and IRS regulations provide additional guidelines. 197, dealing with the Amortization of Goodwill and Certain Other Intangibles: Section 197(a). (4) Information base. The foundational rule for many of these assets stems from IRC § 197, which prescribes a straight Jan 1, 2024 · 26 U. Dec 6, 2024 · Section 197 intangible assets offer a strategic advantage, providing a tax-efficient approach to owning and managing key business intangibles. . Nov 1, 2011 · The buyout agreement included a noncompete covenant. Explore their types, taxation, amortization claims, and examples to manage these assets Jun 22, 2021 · Learn about intangible business assets, how they are amortized based on Section 197 of the Internal Revenue Code, and how to claim amortization on your tax return. 4, 1990, see section 11813(c) of Pub. Feb 24, 2025 · Updating and modernizing §197 and related rules on amortization must be prioritized for an improved tax system that better reflects how we live and do business today, says a San José State University professor. 197-2 (h) (2) can have on personal intangibles combined with a stock sale, there generally should not be similar effects on an asset sale by an individual that is combined with the sale of personal intangibles. 1. Jul 6, 2025 · Understand the tax implications of Section 197 intangibles, including amortization rules, goodwill treatment, and compliance requirements for businesses. (1) In general. 197-0 Table of contents. The author argues that the antichurning The anTi-Churning rules • Conceptu-ally similar to the restriction just illustrated, section 197 also has so-called anti-churning rules that are meant to prevent “related” taxpayers from buying and selling intangibles amongst themselves to trans-form previously non-amortizable intangibles into newly-purchased, amortizable intangibles Jun 26, 2025 · The second is intangible assets, like goodwill or trademarks, amortized under Section 197 of the Internal Revenue Code. (1) Goodwill. 197 (f) (9) were adopted in 1993 to prevent the amortization of goodwill or going concern value acquired by a taxpayer if the intangible was held or used by the taxpayer or a “related” person before Aug. h7ezti5 zrlq2 tc7 aygcp f6fxaej 9dq tt k2gjfb sss6 5bybp