CFR > Title 26 - Internal Revenue > CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY > SUBCHAPTER A—INCOME TAX (Parts 1–19) > PART 1—INCOME TAXES > 1.1251-2—Excess deductions account.

1.1251-2—Excess deductions account.

(a) Establishment and maintenance of account— (1) General rule. With respect to any taxable year beginning after December 31, 1969, any taxpayer who:
(i) Has a farm net loss (as defined in section 1251(e)(2) and in paragraph (b) of § 1.1251-3) for such a taxable year, or
(ii) Has an excess deductions account balance as of the close of such a taxable year

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shall establish (if not previously established) and maintain for purposes of section 1251 an excess deductions account. See section 1251(b)(1). Once an excess deductions account is established (or succeeded to under paragraph (e) of this section in the case of certain corporate transactions and gifts) all entries (including the entries prescribed by paragraph (f) of this section with respect to married taxpayers who file joint returns) with respect to the account must be part of the taxpayer's permanent records for all taxable years for which the account must be maintained. For purposes of applying section 1251 and this section, the term taxpayer in the case of a partnership means each partner of such partnership and in the case of an estate or trust means the estate or trust regardless of whether it is taxable under subpart A or E, subchapter J, chapter 1 of the Code.
(2) Distributions from estate or trust. If farm recapture property is distributed from an estate or trust in a transaction to which section 1251(d) (1) or (2) (relating to exceptions for gifts and transfers at death) applies, then the excess deductions account balance of the estate or trust shall be succeeded to by the distributee in the amount, if any, and manner prescribed in paragraph (e)(2) of this section. For purposes of the preceding sentence only, the rules of paragraph (e)(2) of this section shall be applied by treating each distribution as a gift at the time made. Thus; for example, if all of the farm recapture property of an estate or trust is distributed to a distributee on the date the estate or trust terminates, the distributee will succeed on that date to the excess deductions account balance of the estate or trust.
(3) Exception. A taxpayer is not required to maintain an excess deductions account under subparagraph (1) of this paragraph for a taxable year if:
(i) For such taxable year there would be no additions to the taxpayer's excess deductions account, and
(ii) For the immediately preceding taxable year the balance in the taxpayer's excess deductions account was reduced to zero by reason of section 1251 (b)(3) (relating to subtractions from the account) or section 1251(b)(5) (relating to transfer of account).
(b) Additions to account— (1) General rule. For each taxable year, there shall be added to the excess deductions account an amount equal to the taxpayer's farm net loss. See section 1251(b)(2)(A).
(2) Exceptions. In the case of an individual and, in the case of an electing small business corporation (as defined in section 1371(b) ), subparagraph (1) of this paragraph shall apply for a taxable year:
(i) Only if the taxpayer's nonfarm adjusted gross income (as defined in paragraph (d) of § 1.1251-3) for such year exceeds $50,000, and
(ii) Only to the extent the taxpayer's farm net loss for such year exceeds $25,000.

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The limitations of this subparagraph apply to a person (other than a trust) to whom the tax rates set forth in section 1 are applicable and as prescribed in subparagraph (3) of this paragraph in respect of an electing small business corporation.
(3) Electing small business corporation— (i) Taxable years ending before December 11, 1971. For taxable years ending before December 11, 1971, in the case of an electing small business corporation (as defined in section 1371(b) :
(a) For purposes of subparagraph (2) of this paragraph, the term the taxpayer means such corporation or any one of its shareholders, and the term such year, in the case of a shareholder, means his taxable year with which or within which the taxable year of the corporation ends (see paragraph (d)(2) of § 1.1251-3 for special rules relating to the computation of nonfarm adjusted gross income of a shareholder of an electing small business corporation), and
(b) The limitations in subparagraph (2) of this paragraph shall not apply to the corporation for a taxable year if on any day of such year there is a taxpayer who is a shareholder having, for his taxable year with which or within which the taxable year of such corporation ends, a farm net loss (as defined in paragraph (b) of § 1.1251-3 ).
For purposes of determining whether a shareholder of such corporation has a farm net loss, there shall not be taken into account his pro rata share of farm net income or loss of any other electing small business corporation for such corporation's taxable year ending with or within his taxable year.
(c) The provisions of this subdivision (i) do not apply for purposes of determining whether the shareholder must make an addition to his excess deductions account and the amount of such addition.
(ii) Taxable years ending after December 10, 1971. [Reserved]
(4) Married individuals— (i) Lower limitations for separate returns. If married taxpayers file separate returns, then for purposes of this paragraph each spouse shall be treated as a separate individual. However, in such case, (a) the amount specified in subparagraph (2)(i) of this paragraph shall be $25,000 in lieu of $50,000, and (b) the amount specified in subparagraph (2)(ii) of this paragraph shall be $12,500 in lieu of $25,000. The lower limitations in the preceding sentence shall not apply if the spouse of the taxpayer does not have any nonfarm adjusted gross income for the taxable year. See section 1251(b)(2)(C).
(ii) Joint return. If married taxpayers for a taxable year file a joint return under section 6013, then for purposes of this paragraph they shall for such taxable year be treated as a single taxpayer. For rules applicable to establishing, maintaining, and allocating a joint excess deductions account, see paragraph (f) of this section.
(5) Examples. The provisions of this paragraph may be illustrated by the following examples:

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Example 1. For 1971, the M Corporation which uses the claendar year as its taxable year and which is not an electing small business corporation has a farm net loss of $40,000 and nonfarm taxable income of $45,000. Since subparagraph (2) of this paragraph does not apply to M, it is required to make a $40,000 addition to its excess deductions account.

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Example 2. For 1971, A, an unmarried individual who uses the calendar year as his taxable year, has a farm net loss of $33,000 and nonfarm adjusted gross income of $65,000. Under subparagraph (2) of this paragraph, A is required to make an addition of $8,000 to his excess deductions account (that is, the excess of the farm net loss, $33,000, over the $25,000 amount referred to in subparagraph (2)(ii) of this paragraph). If, however, A were a trust, the limitation in subparagraph (2) of this paragraph would not apply and such trust would be required to add $33,000 (the amount of the entire farm net loss) to its excess deductions account.

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Example 3. H and W each use the calendar year as the taxable year. For 1971, H, a married taxpayer who files a separate return, has a farm net loss of $45,000 and nonfarm adjusted gross income of $60,000. H's spouse W does not have any nonfarm adjusted gross income for 1971. Thus, the lower limitations in subparagraph (4)(i) of this paragraph do not apply. Accordingly, H is required to make an addition of $20,000 to his excess deductions account (that is, the excess of the farm net loss, $45,000, over the $25,000 amount referred to in subparagraph (2)(ii) of this paragraph).

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Example 4. Assume the same facts as in example (3), except that for 1971 W has a farm net loss of $10,000 and nonfarm adjusted gross income of $30,000. Thus, the lower limitations in subparagraph (4)(i) of this paragraph do apply and H is required to make an addition of $32,500 to his excess deductions account (that is, the excess of his farm net loss, $45,000, over the $12,500 amount referred to in subparagraph (4)(i)(b) of this paragraph). Since, however, W did not have a farm net loss in excess of $12,500, she would not be required to make an addition to her excess deductions account. For the result if H and W were to file a joint return, see example (1) of paragraph (f)(6) of this section.

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Example 5. For 1970, the M Corporation, which uses the calendar year as its taxable year and which is an electing small business corporation, has a farm net loss of $35,000 and nonfarm adjusted gross income of $60,000. A, B, and C, the sole equal shareholders of M, are cash method taxpayers and each uses a fiscal year ending on March 31. For the taxable year ending March 31, 1971, A has a farm net loss of $5,000. Thus, as M's taxable year ends within the taxable year of A during which A has a farm net loss, the limitations in subparagraph (2) of this paragraph do not apply with respect to M for 1970. See subparagraph (1) of this paragraph, to add $35,000 to its excess deductions account.

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Example 6. Assume the same facts as in example (5), except that A's farm net loss occurred in his fiscal year ending March 31, 1970, and no shareholder of M has a farm net loss for the fiscal year ending March 31, 1971. Thus, the limitations in subparagraph (2) of this paragraph do apply with respect to M for 1970, and accordingly M is required to add $10,000 to its excess deductions account for 1970 (that is, the excess of M's farm net loss $35,000, over the $25,000 amount referred to in subparagraph (2)(ii) of this paragraph).
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Example 7. Assume the same facts as in example (6), except that M has $45,000 of nonfarm adjusted gross income for 1970 and A, for his taxable year ending March 31, 1971, has $40,000 of nonfarm adjusted gross income, computed without regard to his interest in M. Assume the M paid no dividends. Since, under paragraph (d)(2) of § 1.1251-3 , A's income from M under section 1373(b) is computed on the basis of M's nonfarm adjusted gross income, A's gross income from M is $15,000 (1/3 of $45,000), and A's total nonfarm adjusted gross income is $55,000. Accordingly, M would be required to add $10,000 to its excess deductions account for 1970 for the reasons stated in example (6).

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Example 8. Assume the same facts as in example (7). Assume further that A is one of two equal shareholders in N, another electing small business corporation with a taxable year ending on January 31, and that N for its taxable year ending on January 31, 1971, has a $42,000 nonfarm loss and farm net income of $23,000. Assume that N paid no dividends. Thus, A for purposes of subparagraph (2)(i) of this paragraph, would only have a total of $34,000 of nonfarm adjusted gross income ($55,000) computed per example (7) minus $21,000 (A's share of N's nonfarm net operating loss (1/2 of $42,000) computed in accordance with paragraph (d)(2) of § 1.1251-3 )). Assuming that no other shareholder of M has nonfarm adjusted gross income in excess of $50,000, by reason of the $50,000 limitation in subparagraph (2)(i) of this paragraph, M makes no addition for 1971 to its excess deductions account. (N would make no addition to its excess deductions account as it does not have a farm net loss.) If, however, N were to have a nonfarm loss of only $8,000, A for purposes of subparagraph (2)(i) of this paragraph would have a total of $51,000 of nonfarm adjusted gross income ($51,000 of nonfarm adjusted gross income ($55,000, minus 1/2 of N's nonfarm loss of $8,000)). Hence, with respect to M the result would be the same as in example (7) (and N would make no addition to its excess deductions account since it does not have a farm net loss).

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Example 9. D and E are equal individual shareholders in corporations X, Y, and Z, the stock of each corporation having recently been purchased from a different unrelated person. X, Y, and Z are electing small business corporations. D, E, and the corporations all use the calendar year as the taxable year. For 1970, the farm net income of D and E (determined without regard to their respective pro rata shares of the farm net income or loss of X, Y, and Z) are $100,000 and zero, respectively. For 1970, the farm net income or loss of the corporations are losses of $80,000 and $20,000 for X and Z, respectively, and income of $60,000 for Y. For 1970, the determinations under subparagraph (3)(ii) of this paragraph as to whether a shareholder of corporation X or Z (no determination is necessary with respect to Y since Y does not have a farm net loss) has a farm net loss are made as follows: Determinations as to whether D or E has a farm net loss
As to X As to Z
D E D E
Farm net income (determined without regard to X, Y, and Z) $100,000 $0 $100,000 $0
Pro rata (1/2) share of corporation's farm net income (or loss):
Of X (40,000) (40,000)
Of Y 30,000 30,000 30,000 30,000
Of Z (10,000) (10,000)
Farm net income (or loss) for purposes of determination $120,000 $20,000 $90,000 ($10,000)
Accordingly, since the determination as to X indicates that neither D nor E has a farm net loss, the limitations of subparagraph (2) of this paragraph apply to X. Thus, assuming that X, D, or E has nonfarm adjusted gross income in excess of $50,000, X will add $55,000 to its excess deductions account, i.e., the excess of the farm net loss, $80,000, over the $25,000 amount referred to in subparagraph (2)(ii) of this paragraph. Since, however, the determination as to Z indicates that E has a farm net loss, such limitations do not apply to Z. Thus, the addition for 1970 to Z's excess deductions account is the entire amount of its farm net loss, $20,000.
(c) Subtractions from account— (1) General rule. Under section 1251(b)(3), if there is any amount in the excess deductions account at the close of a taxable year (determined after making any addition required under paragraph (b) of this section for such year but before making any reduction under this paragraph for such year), then the excess deductions account shall be reduced (but not below zero) by subtracting:
(i) An amount equal to (a) the farm net income (as defined in section 1251 (e)(3) and in paragraph (c) of § 1.1251-3) for such year, plus (b) the amount (as determined in subparagraph (3) of this paragraph) necessary to adjust the account for deductions for any taxable year which did not result in a reduction of the taxpayer's tax under subtitle A of the Code for such taxable year or any preceding taxable year, and
(ii) After making any addition to the excess deductions account under paragraph (b) of this section and any reduction under subdivision (i) of this subparagraph for the taxable year, an amount equal to the sum of the amounts recognized as ordinary income solely by reason of the application of section 1251(c)(1). See section 1251(b)(3)(B). Thus, no amount shall be subtracted under this subdivision for gain recognized by reason of the application of section 1245(a)(1) or 1252(a)(1). For effect on computation of farm net loss or income of gain recognized under section 1245(a)(1) upon a disposition of farm recapture property, see paragraph (b)(2) of § 1.1251-3. In the case of an installment sale of farm recapture property, the taxpayer's excess deductions account shall be reduced under this subdivision in the year of such sale by an amount equal to the gain (computed in the year of sale) to be recognized as ordinary income under section 1251(c)(1).
(2) Examples. The provisions of subparagraph (1) of this paragraph may be illustrated by the following examples in which it is assumed that there is no subtraction for lack of tax benefit under subparagraph (3) of this paragraph:

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Example 1. Assume the same facts as in example (3) of paragraph (b)(6) of § 1.1251-1 . M's excess deductions account balance as of the close of 1975 is computed, in accordance with the additional facts assumed, in the table below: M's Excess Deductions Account
(1) Balance January 1, 1975 $26,000
(2) Additions for 1975 0
(3) Subtotal 26,000
(4) Subtractions for 1975 (farm net income 1) 1,000
(5) Excess deductions account limitation on gain recognized as ordinary income under section 1251(c)(1) for 1975 25,000
(6) Subtraction for disposition of farm recapture property:
(a) Gain from disposition of land to which section 1251(c)(1) applies (computed before applying limitation $13,000
(b) Gain from disposition of breeding herd to which section 1251(c)(1) applies (computed before applying limitation) 14,000
(c) Sum of lines (a) and (b) 27,000
(d) Excess deductions account limitation (amount in line (5)) 25,000
(e) Gain recognized as ordinary income under section 1251(c)(1) (lower of line (6)(c) or line (6)(d) 25,000
(7) Balance December 31, 1975 0
1 Computed by treating the section 1245 gain of $6,000 under paragraph (b)(1)(ii) of § 1.1251-3 as gross income derived from the trade or business of farming.
For allocation of the $25,000 of gain recognized as ordinary income to the land and herd, and for treatment of the gain recognized in excess of $25,000 see example (3) of paragraph (b)(6) of § 1.1251-1 .

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Example 2. A is an unmarried individual who uses the calendar year as his taxable year. In 1971, A makes a single disposition of farm recapture property (other than land) realizing a gain of $46,000 of which $15,000 is recognized as ordinary income under section 1245(a)(1). The gain to which section 1251(c)(1) applies (computed before applying the excess deductions account limitation in section 1251(c)(2)(A) and paragraph (b)(4)(i) of § 1.1251-1 ) is $31,000 (i.e., $46,000 minus $15,000). The treatment of the gain realized on the disposition in excess of the $15,000 recognized as ordinary income under section 1245(a)(1) and the balance in A's excess deductions account as of the close of 1971 is computed, in accordance with the facts assumed, in the table below:
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A's Excess Deductions Account
(1) Balance January 1, 1971 $50,000
(2) Additions for 1971:
(a) Farm net loss for 1971 1 $5,000
(b) Less amount in paragraph (b)(2)(ii) of this section 25,000
(c) Total additions for 1971 0
(3) Subtotal 50,000
(4) Subtractions for 1971 0
(5) Excess deductions account limitation on gain recognized as ordinary income under section 1251(c)(1) for 1971 50,000
(6) Subtraction for dispositions of farm recapture property:
(a) Gain to which section 1251(c)(1) applies (computed before applying limitation) 31,000
(b) Limitation (amount in line (5) 50,000
(c) Gain recognized as ordinary income under section 1251(c)(1) lower of line 6(a) or line 6(b) 31,000
(7) Balance December 31, 1971 19,000
1 Computed by treating the section 1245 gain of $15,000 under paragraph (b)(1)(ii) of § 1.1251-3 as gross income derived from the trade or business of farming.
(3) Amount necessary to adjust the excess deductions account with respect to deductions which did not result in a reduction of the taxpayer's tax— (i) In general. Under section 1251(b)(3)(A), a subtraction is made from the excess deductions account to adjust the account for deductions that did not result in a reduction of the taxpayer's tax for the taxable year or any preceding taxable year. The amounts to be subtracted are determined under subdivisions (ii) and (iii) of this subparagraph in accordance with the rules in subdivision (iv) of this subparagraph. This subtraction shall be made before determining the amount of gain to which section 1251(c) applies. The amount subtracted under subdivision (ii) of this subparagraph is a temporary subtraction made solely to determine the amount in the excess deductions account for purposes of the limitation in section 1251(c)(2).
(ii) Temporary subtraction. The amount temporarily subtracted from the excess deductions account for a taxable year is the sum of the farm portion of (a) any net operating loss for such taxable year which does not reduce taxable income (computed without regard to the deduction under section 172(a)) in a prior year, and (b) any net operating loss from a prior taxable year which is carried to such taxable year but which does not reduce taxable income (computed without regard to the deduction under section 172(a)) in such taxable year.
(iii) Permanent subtraction. The amount permanently subtracted from the excess deductions account for a taxable year is the excess of the farm portion of any net operating loss which may be carried to the preceding year (reducing by the portion of such loss which reduced taxable income (computed without regard to the deduction under section 172(a)) for such preceding year) over the amount of such loss which may be carried to the taxable year, but the subtraction shall not be made earlier than the taxable year in which the excess deductions account is increased by reason of such loss.
(iv) Rules of application. For purposes of this subparagraph, the following rules shall apply:
(a) The farm portion of a net operating loss is that portion of such loss attributable to the trade or business of farming. Such portion and the remaining portion (hereinafter referred to as the nonfarm loss) shall be absorbed pro rata. If a farm net loss is not added to the excess deductions account in the year in which such loss occurs, the net operating loss (if any) for such year shall be treated as a nonfarm loss.
(b) In the case of an individual (other than a trust), the farm portion of a net operating loss shall be decreased by an amount, if any, equal to the excess of $25,000 (or the amount determined under paragraph (b)(2)(ii) of this section) over the nonfarm adjusted gross income. Such amount shall be added to the nonfarm portion of such net operating loss.
(c) The amounts considered as reducing taxable income under subdivision (ii) of this subparagraph in the taxable year shall be determined on the basis of a tentative computation of taxable income for such year in which the gain realized from the disposition of property to which section 1251(c)(1) applied shall be computed without regard to the excess deductions account limitation.
(v) Example. The provisions of this subparagraph may be illustrated by the following example:

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Example: A is an unmarried individual who uses the calendar year as his taxable year. For the years 1970 through 1974, A's items of income and deductions are as shown in the table below. A's personal deductions are disregarded. A had no income or loss for any year prior to 1970. Based upon such amounts and the computations shown below, A must recognize as ordinary income under section 1251(c)(1), $35,325 for 1971, $10,000 for 1972, $3,925 for 1973, and $150,000 for 1974.
Amounts assumed 1970 1971 1972 1973 1974
(a) Farm net income ($250,000) $20,000 $5,000 ($75,000) ($10,000)
(b) Nonfarm income 55,000 (82,000) 30,000 10,000 200,000
(c) Gain which would be recognized as ordinary income under 1251(c) (computed without regard to the EDA limitation) (hereinafter referred to as farm property disposition) 88,000 10,000 2,000 150,000
(d) Personal exemption 625 675 750 750 750
(e) Net operating loss (NOL) (computed per section 172(c)) (195,000) (45,000)
I. COMPUTATIONS FOR 1971
1. Excess Deductions Account (EDA) Limitation for 1971:
a. EDA on December 31, 1970:
1970 Farm net loss 250,000
Less (25,000)
225,000 225,000
b. Less farm net income for 1971 (20,000)
c. EDA before temporary subtraction 205,000
d. Less temporary subtraction per subdivision (ii)(b):
Aggregate farm NOL carryover to 1971 195,000
Less tentative farm NOL deduction for 1971:
Farm net income 20,000
Nonfarm income (82,000)
Farm property disposition 88,000
Exemption (675)
Tentative taxable income 25,325
Tentative NOL reducing taxable income 25,325 (25,325)
169,675 (169,675)
e. EDA limitation for 1971 35,325
2. 1971 Taxable Income:
a. Farm net income 20,000
b. Nonfarm income ($82,000)
c. Farm property disposition 88,000
d. Exemption (675)
e. Section 1202 deduction:
Farm property disposition $88,000
Less amount treated as ordinary income under section 1251(c) (lesser of amount of gain on line 1(e)) 35,325
Capital gain 52,675
Less 50 percent deduction 26,337 (26,338)
f. 1971 Taxable income (1,013)
II. COMPUTATIONS FOR 1972
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1. Excess Deductions Account Limitation for 1972:
a. EDA (line 1(c) above) 205,000
b. Less recapture in 1971 (35,325)
c. Less farm net income for 1972 (5,000)
d. Less permanent subtraction per subdivision (iii):
1970 Farm NOL carryover to 1971 195,000
Less 1970 farm NOL carryover to 1972 (computed per section 172(b)(2)):
Farm NOL to 1971 $195,000
Less 1971 taxable income computed per section 172(b)(2):
Farm net income $20,000
Nonfarm income (82,000)
Farm property disposition 88,000
26,000 (26,000)
Farm NOL carryover to 1972 169,000 ($169,000)
26,000 ($26,000)
e. EDA before making temporary subtractions 138,675
f. Less temporary subtraction per subdivision (ii)(b):
Farm NOL carryover to 1972 169,000
Farm net income 5,000
Nonfarm income 30,000
Farm recapture disposition 10,000
Exemption (750)
Tentative taxable income 44,250
Tentative NOL reducing taxable income 44,250 (44,250)
124,750 (124,750)
g. EDA limitation for 1972 13,925
2. Taxable Income for 1972:
a. Farm net income 5,000
b. Nonfarm income 30,000
c. Farm property disposition 10,000
d. Exemption (750)
e. Section 1202 deduction:
Farm property disposition 10,000
Less amount treated as ordinary income under section 1251(c) (lesser of amount of gain on line 1(g)) 10,000 0
f. Taxable income before NOL deduction 44,250
g. Net operating loss deduction (44,250)
h. Taxable income for 1972 0
III. COMPUTATIONS FOR 1973
1. Excess Deductions Account Limitation for 1973:
a. Line 1(e) above 138,675
b. Less recapture in 1972 (10,000)
c. Less permanent subtraction per subdivision (iii):
1970 Farm NOL carryover to 1972 169,000
Less 1970 Farm NOL reducing taxable income in 1972 (44,250)
124,750 124,750
Less 1970 Farm NOL carryover to 1973 computed per section 172(b)(2):
Farm NOL to 1972 169,000
1972 Taxable income computed per section 172(b)(2):
Farm net income $5,000
Nonfarm income 30,000
Farm recapture disposition 10,000
45,000 ($45,000)
Farm NOL carryover to 1973 124,000 ($124,000)
750 ($750)
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d. EDA before making temporary subtractions $127,925
e. Less temporary subtraction per subdivision (ii)(a)-zero (since 1973 farm loss treated as nonfarm addition to NOL per subdivision (iv)(a)) 0
f. Less temporary subtraction per subdivision (ii)(b): Aggregate farm NOL carryover to 1973 $124,000
Less tentative farm NOL deduction for 1973:
Farm net income ($75,000)
Nonfarm income 10,000
Farm property disposition 30,000
Exemption (750)
Tentative taxable income (44,250)
Tentative NOL reducing taxable income 0 0
124,000 (124,000)
g. EDA limitation for 1973 3,925
2. Taxable Income 1973:
a. Farm net income (75,000)
b. Nonfarm income 10,000
c. Farm property disposition 20,000
d. Exemption (750)
e. Section 1202 deduction:
Farm property disposition 20,000
Less amount treated as ordinary income under section 1251(c) (lesser of amount of gain on line 1(g)) 3,925
Capital gain 16,075
Less 50 percent deduction 8,038 (8,037)
f. Taxable income for 1973 (53,787)
IV. COMPUTATIONS FOR 1974
1. Excess Deductions Account Limitation for 1974:
a. Line 1(d) above 127,925
b. Less recapture in 1973 (13,925)
c. Farm loss for 1974 10,000
Plus farm NOL deduction (see § 1.1251-3(b)(3) ) 45,000