Percent of incorrectly detected duplicated
pairs Vs Attributes
The duplicated loss as to the shares sold is $6 (20% x ($130-$1(100)); thus, the entire $6 loss is suspended.
The new regulations also include a substitute asset rule that suspends a member's loss recognized on an asset disposition (other than of a member's stock) when the member's basis in the disposed asset was determined by reference to a member's basis in stock for which there was a duplicated loss, and immediately after the disposition, the subsidiary is a group member.
Because the group has been allowed to take the subsidiary's deductions and losses as they are recognized, any duplicated losses inherent in the subsidiary's stock should be eliminated.
The proposed regulations also include a substitute-asset rule, in which a member's loss on an asset disposition other than S stock would be suspended if(1) the member's asset basis was determined by reference to the basis of an S, for which there was a duplicated loss, and (2) immediately after the transaction, S remained a group member.
The proposed regulations contain a rebuttable presumption that all deductions and losses are attributable first to the duplicated loss that gave rise to a suspended stock loss.
This rule would apply if (1) a group recognizes an allowable loss on an S stock disposition that generates a duplicated loss, (2) as a result of that disposition (or another), S leaves the group and (3) within the 10-year period beginning on the date that S left, its loss is reimported to the group.
However, losses are disallowed only to the extent of the sum of three "factors": (1) extraordinary gain dispositions, (2) positive investment adjustments and (3) duplicated losses.
For purposes of this item, only the duplicated loss factor (DLF) will be considered, because this was the factor invalidated by the Federal Circuit in Rite Aid.
1502-32(b)(4) are not duplicated
losses subject to disallowance.
Under the economic loss formula (ELF) the amount of loss disallowed or the amount of basis reduction with respect to a share of stock cannot exceed the share's sum of (1) extraordinary gain dispositions (EGADs), (2) positive investment adjustments (PINAs) and (3) duplicated loss.
The ELF attempts to disallow losses that could be duplicated at a later date.
After CD-Replicator is opened, the user places the CD to be duplicated
into the recorder, allowing the program to read and temporarily store all the file information from the disc to the hard drive.