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Old 08-27-2003, 10:57 AM   #16
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wonk did you get my email?
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Old 10-30-2003, 07:55 PM   #17
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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.
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Old 02-16-2010, 01:23 PM   #18
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Re: Welcome to Tax!

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Originally Posted by taxwonk View Post
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.
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Old 02-16-2010, 02:23 PM   #19
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Re: Welcome to Tax!

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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!
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Old 02-16-2010, 02:34 PM   #20
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Re: A technical question

Quote:
Originally Posted by taxwonk View Post
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)
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Old 02-16-2010, 02:38 PM   #21
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Re: Welcome to Tax!

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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.
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Old 02-16-2010, 02:56 PM   #22
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Re: A technical question

Quote:
Originally Posted by taxwonk View Post
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.
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Old 02-16-2010, 03:03 PM   #23
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Re: Welcome to Tax!

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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
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Old 02-16-2010, 03:18 PM   #24
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Re: A technical question

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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.
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Old 02-18-2010, 02:50 PM   #25
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Re: Welcome to Tax!

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yeah, sorry wonk. plus, RT doesn't like to make someone a mod who is on so many ignore lists
2
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Old 02-18-2010, 04:00 PM   #26
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Re: Welcome to Tax!

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2
Hank said that? I didn't know. I had him on ignore.
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Old 02-18-2010, 04:04 PM   #27
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Re: Welcome to Tax!

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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.
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Old 02-26-2010, 02:23 PM   #28
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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
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Old 02-26-2010, 08:07 PM   #29
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Re: Welcome to Tax!

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yeah, sorry wonk. plus, RT doesn't like to make someone a mod who is on so many ignore lists
Who is on ignore?!?!
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Old 02-26-2010, 08:16 PM   #30
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Re: Welcome to Tax!

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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
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