26 C.F.R. § 1.663(c)-2
Computation of distributable net income.
Cite as 26 C.F.R. § 1.663(c)-2 (1998 ed.)
The amount of distributable net income for any share under section 663(c) is computed for each share as if each share constituted a separate trust. Accordingly, any deduction or any loss which is applicable solely to one separate share of the trust is not available to any other share of the same trust.