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If the loss is on the business portion, only it is a direct expense and the entire loss is includable. The income would be currently includable, except to the extent of any contingent payments, which would be recognized when accrued or received, as the case may be. Thus, for example, where a Code provision refers to a "loss" of the taxpayer from an activity, for purposes of the alternative minimum tax the existence of a loss is determined with regard to the items that are includable and deductible for minimum tax, not regular tax purposes. |
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