(taxpayer is 50 percent partner in LLC, and LLC executed loan modification agreement with bank resulting in debt cancellation income to taxpayer which wasn't reported on Form 1065 or Schedule K-1; taxpayer's Form 1040 prepared by different preparer unaware of taxpayer's debt discharge income and, as result, no election made under I.R.C. Sec. 108(c)(3)(C) and Treas. Reg. Sec. 1.108-5(b) to reduce basis of depreciable property and exclude debt discharge from qualified real property business debt; request for extension of time to make election granted; 45-day extension granted).