There was an interesting Tax Court decision in a case involving this issue, which was blogged here:

https://taishofflaw.com/2023/11/28/as-such/

Which is easier to read than the opinion itself, available here:

https://assets.kpmg.com/content/dam/kpmg/us/pdf/2023/11/tnf-tax-court-soroban-nov28-2023.pdf 

I predict there will be two or three questions posted here in 2024, about this issue.  The answer, of course, is "depends on facts and circumstances."