It generally is not necessary to quantify the effects of positive evidence unless significant negative evidence exists that leads the enterprise to conclude it is more likely than not some or all of the deferred tax assets will not be realized
If the home's FMV at the end of the two-year period is $275,000, J's and K's realized
gain on a cash sale would be $275,000 (i.
Estimation of the marginal tax rate also would require knowledge of when deferred tax liabilities or assets will be realized
if an enterprise concludes a valuation allowance is necessary to reduce a deferred tax asset to an amount that is more likely than not to be realized
All of the gain realized
(up to an amount equal to the OID) would be ordinary income.
Replacement period: For most involuntary conversions, the taxpayer must replace the converted property within the period beginning on the date of disposition or the earliest date of threat of condemnation, and ending two years after the close of the first tax year in which gain is realized
The administrator calculated the realized
gain or loss using a weighted-average market value as the adjusted basis of the seven shares.
In the context of a sale or disposition of property under [section] 1001, the extinguishment of the obligation to repay is not ordinary income; instead, the amount of the canceled debt is included in the amount realized
and enters into the computation of gain or loss on the disposition of property.