Question: Under section 3 6 2 ( e ) ( 2 ) the decrease is allocated based on relative built - in losses, whereas when allocating

Under section 362(e)(2) the decrease is allocated based on relative built-in losses, whereas when allocating current E&P it is allocated based on relative distribution amounts, whereas when allocating the holding period for a fragmented holding period it is allocated based on the relative FMV of the contributed assets, whereas when allocating basis in a section 305(a) stock distribution transaction it is allocated based on the relative FMV of the stock (or stock rights) received if of different types.
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