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- Partial Disposition of Business Assets/Activity with PAL & Depreciation Recapture
Partial Disposition of Business Assets/Activity with PAL & Depreciation Recapture
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fcwm
Level 2
11-15-2023
11:15 AM
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Client purchased vans to rent out through a truckshare program 3 years ago. They took 100% depreciation in year 1 and still have a substantial suspended loss that has carried over. They are now exiting this business and selling the vans. They have sold 5 out of the 6 but don't think they can get the final van sold this year. Are they able to utilize their PAL carryover against the depreciation recapture they'll face this year, even though this isn't a total disposition of the activity (since there's one van left to be sold next year?). Does it qualify as a partial disposition even though it's not exactly "substantially all" of the activity?
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