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The DOLLARDE function converts a dollar value expressed as a fraction to a decimal amount. It also uses a second argument to specify the denominator of the fractional part. The following formula, for example, returns 9.25.



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exceeds the amount of loss disallowed under the general modi ed wash sale rule: (a) successor position ; (b) an offsetting position to the loss position; or (c) an offsetting position to any successor position [Treas Reg 11092(b)-1T(a)(2)]58 There are a number of additional complexities involved in applying the general loss deferral rules and the modi ed wash sale rules, which are beyond the scope of this chapter Any loss that is currently disallowed under the loss deferral rules discussed above is carried forward and treated as sustained in the following year, to the extent the deferral rules do not apply in that year [Treas Reg 11092(b)-1T(b)] Treasury regulations provide detailed guidance for determining when a taxpayer can claim a deduction for a deferred loss that is carried forward [Treas Reg 11092(b)-1T(b) and 1T(g), Exs 19, 20, and 21].





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Design Machine Group Department of Architecture University of Washington, Seattle, WA 98195-5720 Tel: 206.543.1604

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Summary

If the disposition of a loss position would result in a capital loss, then that character is preserved once the loss is allowed as a deduction, regardless of how a gain or loss on any successor position would be treated [Treas Reg 11092(b)-1T(c)(1)] Similarly, if the original loss position would have been subject to the special 60% long-term/40% short-term capital loss treatment provided under Code section 1256, the deferred loss is also subject to that treatment, even if the gain or loss on a successor position would be treated as a 100% long-term or 100% short-term capital gain or loss [Treas Reg 11092(b)-1T(c)(2)] Positions in a straddle are also subject to special modi ed short sale rules [Code sec 1092(b)(1)], which operate in a manner similar to Rule 2 governing short sales, with the concept of offsetting positions substituting for substantially identical property.

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N OT E Python allows you to use a lowercase L, but it is recommended that you use only an uppercase L to avoid confusion with the number 1. Even if you assign a long integer to a variable that has a lowercase L, Python displays long integers with an uppercase L.

year, the S&Ls rallied sharply. In the fall of 1989, it can be seen that the peak in the S&L stocks occurred at about the same time that the CRB Index was breaking its yearlong down trendline. Since the S&Ls are so closely tied to the bond market, and the bond market moves inversely to the CRB Index, it shouldn't be surprising to discover a strong inverse relationship between the S&Ls and the CRB Index.

In certain cases, these special rules may terminate a taxpayer s holding period in a straddle position For example, when the taxpayer has held property for less than one year and the property constitutes a position in a straddle, the holding period for the property would be deemed to begin at the time the offsetting position or positions are disposed of (This holding-period termination rule does not apply to positions the taxpayer held for at least a year before establishing the straddle that includes the positions [Treas Reg 11092(b)-2T(a)(2)]) Further, a loss on the disposition of a straddle position (a loss position ) is generally treated as a long-term capital loss if (a) on the date the taxpayer entered into the loss position, the taxpayer held directly, or indirectly through a related person or ow-through entity (eg.

dz1 (t ) 1 (t ) dz2 (t ) = 2 (t ) dt K K dzn (t ) n (t )

The satellite spot-beams are steered in order to compensate the satellite motion and to generate fixed cells on the Earth (the Earth surface has been divided in approximately 500 cells). According to geometrical criteria and resource allocation optimization (including the shutting down process in non-operating zones), a traffic hand-over, which is transparent to the user, occurs between satellites from time to time. Following the instructions received from the MMC, the satellite creates a spot-beam above that gateway for the duration of the assignment. After the release of the spotbeam, the corresponding resources are made available to another gateway. The process is illustrated by Figure AP6.1-8.

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