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-   -   Welcome to Tax! (http://www.lawtalkers.com/forums/showthread.php?t=90)

runaway 08-27-2003 10:57 AM

wonk did you get my email?

taxwonk 10-30-2003 07:55 PM

A technical question
 
Assuming there's anybody out there...

In determining a capital loss carryback, is a net foreign capital loss allocated directly to those members foreign cap gains in the Carryback year, or is it apportioned among members to whom the loss is attributable under Reg. 1.1502-21 and -22?

I'm having a hell of a time finding anything to hang my hat on and the regs are less than clear.

Mmmm, Burger (C.J.) 02-16-2010 01:23 PM

Re: Welcome to Tax!
 
Quote:

Originally Posted by taxwonk (Post 416433)
If memory serves there was a tax board here for about an hour, until I asked why.


It's still here, but you pissed all over it for other reasons.

taxwonk 02-16-2010 02:23 PM

Re: Welcome to Tax!
 
Quote:

Originally Posted by Mmmm, Burger (C.J.) (Post 416434)
It's still here, but you pissed all over it for other reasons.

Yep, me and three visitors from the Icky Board days. Mod me up, Dude!

Hank Chinaski 02-16-2010 02:34 PM

Re: A technical question
 
Quote:

Originally Posted by taxwonk (Post 44709)
Assuming there's anybody out there...

In determining a capital loss carryback, is a net foreign capital loss allocated directly to those members foreign cap gains in the Carryback year, or is it apportioned among members to whom the loss is attributable under Reg. 1.1502-21 and -22?

I'm having a hell of a time finding anything to hang my hat on and the regs are less than clear.

in a word, yes e.g. in re cicero, 45 Dec's Comm (1945)

Flinty_McFlint 02-16-2010 02:38 PM

Re: Welcome to Tax!
 
Quote:

Originally Posted by taxwonk (Post 416441)
Yep, me and three visitors from the Icky Board days. Mod me up, Dude!

I'm sorry, the position has been filled by a more qualified candidate.

Greedy,Greedy,Greedy 02-16-2010 02:56 PM

Re: A technical question
 
Quote:

Originally Posted by taxwonk (Post 44709)
Assuming there's anybody out there...

In determining a capital loss carryback, is a net foreign capital loss allocated directly to those members foreign cap gains in the Carryback year, or is it apportioned among members to whom the loss is attributable under Reg. 1.1502-21 and -22?

I'm having a hell of a time finding anything to hang my hat on and the regs are less than clear.

Isn't the answer here whatever your client wants? I mean, if you can't hang your hat on something, they're both logical.

Hank Chinaski 02-16-2010 03:03 PM

Re: Welcome to Tax!
 
Quote:

Originally Posted by Flinty_McFlint (Post 416443)
I'm sorry, the position has been filled by a more qualified candidate.

yeah, sorry wonk. plus, RT doesn't like to make someone a mod who is on so many ignore lists:(:(

taxwonk 02-16-2010 03:18 PM

Re: A technical question
 
Quote:

Originally Posted by Greedy,Greedy,Greedy (Post 416444)
Isn't the answer here whatever your client wants? I mean, if you can't hang your hat on something, they're both logical.

This is what I would expect from a scotch drinker.

PresentTense Pirate Penske 02-18-2010 02:50 PM

Re: Welcome to Tax!
 
Quote:

Originally Posted by Hank Chinaski (Post 416445)
yeah, sorry wonk. plus, RT doesn't like to make someone a mod who is on so many ignore lists:(:(

2:o

taxwonk 02-18-2010 04:00 PM

Re: Welcome to Tax!
 
Quote:

Originally Posted by PresentTense Pirate Penske (Post 416749)
2:o

Hank said that? I didn't know. I had him on ignore.

PresentTense Pirate Penske 02-18-2010 04:04 PM

Re: Welcome to Tax!
 
Quote:

Originally Posted by taxwonk (Post 416763)
Hank said that? I didn't know. I had him on ignore.

Actually, that was just a test to see if you had me on ignore. You passed. :):):)

LessinSF 02-26-2010 02:23 PM

Re: Welcome to Tax!
 
How can I earn $108 million and pay no state income tax? http://taxprof.typepad.com/taxprof_b...odger-la-.html

ltl/fb 02-26-2010 08:07 PM

Re: Welcome to Tax!
 
Quote:

Originally Posted by Hank Chinaski (Post 416445)
yeah, sorry wonk. plus, RT doesn't like to make someone a mod who is on so many ignore lists:(:(

Who is on ignore?!?!

Hank Chinaski 02-26-2010 08:16 PM

Re: Welcome to Tax!
 
Quote:

Originally Posted by ltl/fb (Post 417969)
Who is on ignore?!?!

wonk and GGG are widely ignored. penske and I try to talk people into not ignoring them and just scrolling past but it seems every week they do something wrong:confused:


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