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08-27-2003, 10:57 AM
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#1
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wonk did you get my email?
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10-30-2003, 07:55 PM
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#2
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Wild Rumpus Facilitator
Join Date: Mar 2003
Location: In a teeny, tiny, little office
Posts: 14,167
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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.
__________________
Send in the evil clowns.
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02-16-2010, 01:23 PM
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#3
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Moderator
Join Date: Mar 2003
Location: Pop goes the chupacabra
Posts: 18,532
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Re: Welcome to Tax!
Quote:
Originally Posted by taxwonk
If memory serves there was a tax board here for about an hour, until I asked why.
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It's still here, but you pissed all over it for other reasons.
__________________
[Dictated but not read]
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02-16-2010, 02:23 PM
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#4
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Wild Rumpus Facilitator
Join Date: Mar 2003
Location: In a teeny, tiny, little office
Posts: 14,167
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Re: Welcome to Tax!
Quote:
Originally Posted by Mmmm, Burger (C.J.)
It's still here, but you pissed all over it for other reasons.
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Yep, me and three visitors from the Icky Board days. Mod me up, Dude!
__________________
Send in the evil clowns.
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02-16-2010, 02:38 PM
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#5
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Moderator
Join Date: Mar 2003
Location: i put on my robe and wizard hat
Posts: 4,838
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Re: Welcome to Tax!
Quote:
Originally Posted by taxwonk
Yep, me and three visitors from the Icky Board days. Mod me up, Dude!
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I'm sorry, the position has been filled by a more qualified candidate.
__________________
I'm going to become rich and famous after I invent a device that allows you to stab people in the face over the internet.
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02-16-2010, 03:03 PM
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#6
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Proud Holder-Post 200,000
Join Date: Sep 2003
Location: Corner Office
Posts: 86,149
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Re: Welcome to Tax!
Quote:
Originally Posted by Flinty_McFlint
I'm sorry, the position has been filled by a more qualified candidate.
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yeah, sorry wonk. plus, RT doesn't like to make someone a mod who is on so many ignore lists 
__________________
I will not suffer a fool- but I do seem to read a lot of their posts
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02-16-2010, 02:34 PM
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#7
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Proud Holder-Post 200,000
Join Date: Sep 2003
Location: Corner Office
Posts: 86,149
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Re: A technical question
Quote:
Originally Posted by taxwonk
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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in a word, yes e.g. in re cicero, 45 Dec's Comm (1945)
__________________
I will not suffer a fool- but I do seem to read a lot of their posts
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02-16-2010, 02:56 PM
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#8
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Registered User
Join Date: Mar 2003
Location: Government Yard in Trenchtown
Posts: 20,182
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Re: A technical question
Quote:
Originally Posted by taxwonk
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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Isn't the answer here whatever your client wants? I mean, if you can't hang your hat on something, they're both logical.
__________________
A wee dram a day!
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02-16-2010, 03:18 PM
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#9
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Wild Rumpus Facilitator
Join Date: Mar 2003
Location: In a teeny, tiny, little office
Posts: 14,167
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Re: A technical question
Quote:
Originally Posted by Greedy,Greedy,Greedy
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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This is what I would expect from a scotch drinker.
__________________
Send in the evil clowns.
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