The IRS has opposed these discounts, arguing that a decedent's fractional interest should be aggregated
with fractional interests owned by family members in the same property.
Wilcke W, Baumler R, Deschauer H, Kaupenjohann M, Zech W (1996) Small scale distribution of AI, heavy metals, and PAHs in an aggregated
In determining the taxable income of an individual, S corporation or partnership, the net income (or loss) from all of the trades or businesses actively conducted by the individual, S corporation or partnership must be aggregated
. Items of income derived from the active conduct of a trade or business include Sec.
Under the UNICAP aggregation rules, gross receipts from all the hospital's taxable subsidiaries are aggregated
with the gross receipts from all hospital unrelated business activities to determine whether gross receipts exceed $10 million.
That is, percentage depletion in excess of basis must be netted against any new aggregation in determining the adjusted basis of newly aggregated