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Estate's beneficiaries aren't entitled to an estate's unused loss carryovers — In Chief Counsel Advice 201047021 (Nov. 26, 2010), the beneficiaries of an estate weren't entitled to deduct unused carryover losses attributable to the insolvent estate.
The residue under the taxpayer's will passed to the taxpayer's spouse, and then, upon the spouse's death, in equal shares to the descendants of four individuals. At the time of the taxpayer's death, the taxpayer had unpaid
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