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El consultante pregunta si puede imputarse una pérdida patrimonial por la conclusión del concurso de Fórum Filatélico tras haber recibido una donación de créditos de su madre. La DGT responde que la pérdida debe atribuirse a quien ostentaba la titularidad en el momento en que se produjo la pérdida, es decir, cuando se dictó la sentencia de conclusión del concurso.
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