Your client, Manny Mendacious, invested $$70,000$ in the stock of a new start$-$up company that opened a chain of fried pickle fast$-$food restaurants called The Cooked Cucumber. As might be expected, this venture has not been very successful, and Manny$$s stock has lost its value. Manny knows that worthless securities are normally treated as a capital loss, which means the $$3,000$ annual maximum deduction and other limits apply. While talking to one of his co$-$investors, he discovers that his tax adviser $($Shamus Sham, the taxman$)$ contends that if a taxpayer $$abandons$$ a security, it is not subject to the capital loss limitation$.$ Manny is very excited about this and is anxious to assert he $$abandoned$$ the Cooked Cucumber stock and deduct the entire $$70,000$ loss in the current year.

a$.$ Locate the regulation that deals with this situation. Give the regulation$$s citation and when the regulation was finalized.

b$.$ Review the regulation. Does it raise a need for new information to solve this question?

c$.$ Are you able to reach a conclusion about the research question from this regulation? If so$,$ what is your conclusion$($s$)?$

d$.$ Does the code allow for Manny to treat his loss as ordinary if The Cooked Cucumber stock meets certain requirements?