Aggregation of losses on participant death or retirement: proportionate reduction converts to preceding-year loss for unincorporated bodies.

Unabsorbed current losses of an unincorporated body for the financial year ending on a participant's retirement or death are reduced in proportion to that participant's share; the reduced amount is treated as the unabsorbed preceding year loss (from ordinary or special sources) for the immediately following financial year, with those references construed accordingly and the provision prevailing over inconsistent Code provisions.

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