The Section 382 - Steptoe & Johnson
General Rule. Losses were disallowed, except losses allowed to the extent that they exceeded (i) extraordinary gain dispositions, (ii) positive investment adjustments, and (iii) duplicated losses. Treas. Reg. § 1.1502-20(c)(1). If a loss was disallowed, the common parent was entitled to some relief under Treas. Reg. § 1.1502-20(g). ................
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