This revenue ruling addresses whether section 267(b)(5) of the Internal Revenue Code of 1954 prohibits a deduction of a loss sustained from the sale of personally owned securities between individuals who are fiduciaries of trusts established by the same grantor. It concludes that such deductions are not prohibited when the transactions are conducted with personal funds and not in the capacity as fiduciaries.
documents/EFTA00597073.pdf
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