Rev. Rul. 54-207

A capital loss carryover provided by section 117(e) of the Internal Revenue Code resulting from a capital loss incurred by a decedent is not deductible by his estate. A capital loss sustained by a decedent during his lifetime is deductible only in the return filed on his behalf. There can be no capital loss carryover from the decedent to his estate for the reason that the decedent and the estate are separate tax entities. See New Colonial Ice Company v. Helvering, 292 U. S. 435, Ct. D. 841, C. B. XIII-1, 194; Estate of R. R. Russell et al. v. Commissioner, 34 BTA 715; I. T. 1562, C. B. II-1, 33 (1923).