[4830-01-p]

The unrecognized section 987 gain or loss when aggregated with similar amounts for prior years (that were not previously taken into account) yields a pool of “net unrecognized section 987 gain or loss” all or part of which is to be triggered upon a remittance or termination. E. Section 1.987-5 Recognition of Section 987 Gain or Loss. ................
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