Revenue Procedure 2014-20 provides a safe harbor under which the Internal Revenue Service will, under certain, defined circumstances, treat indebtedness that is secured by 100 percent of the ownership interest in a disregarded entity that holds real property as indebtedness that is secured by real property for purposes of § 108(c)(3)(A) of the Internal Revenue Code.  This revenue procedure will assist taxpayers with so-called “mezzanine” financing in workouts and similar circumstances.