▲ 2 r/technicaltax
Sec. 267d Question
I hope someone has some experience with this.
Can't find good research on if the character of the disallowed loss changes between related parties.
In my example Related Party 1 (RP1) sold personal property to Related Party 2 (RP2). Loss would have been capital loss to RP1. RP2 sells the personal property for a gain. RP2 is in the business of selling this personal property.
Seems wild to think that the disallowed loss would change character, and reduce ordinary and S/E income, but can't find anything to confirm or deny.
u/b0b_ross — 6 days ago