For years London has seemed like the best and worst of the property market. On the one hand, it has been at the centre of the biggest bang in the loud boom of the UK housing market, with >http://www.assetz.co.uk/">London property prices comfortably ou…

Tom Jelke,
Taxpayer

Isn’t the IRS commissioner mr. shaked a bit silly for comparing carryforward loss to built in capital gain tax liability?

Carryforward loss is something that could be measured with certainty, which is why you can discount it to the present.

The present value of tax liability is today’s value. It makes sense that since CCC’s securities won’t be sold today, the tax liability wouldn’t be the same and would change throughout the years. But the possibility lies that CCC could sell all securities whenever they want.

And it confuses me why IRS would assume the stock will not appreciate and would want to bring this case to the supreme court.

I mean you pretty much have to assume today’s value as the present value since there would be too much uncertainty in estimating the time and discount rate in the formula.

when the stock appreciates, tax appreciates. which is why you can’t discount only the tax liability when computing the current value of CCC. You would have to discount the securities worth too. It could go up or go down.

i don’t understand what’s so hard to understand about this?

thank goodness the 11th circuit understands this simple logic.