it is found, once its accounts have been prepared, that company A has a tax loss of $10,000. It is anticipated that Company B will be in profit and that the amount of the taxable profit will be about $2,000, ie less than the amount of Company A's loss. Company B's accounts, however, have still to be prepared as the accountants are waiting on further information from their clients. That information will be arriving in a few days. There is still time to file an election and the question is whether Company A can now elect to offset some of its loss up to the amount of the profit company's profit by using a formula, which formula will simply be that the amount to be offset will be the amount of Company B's profit. The answer is that this is permissible because: the notice will be given in time; the amount will be subsequently identified as a specific dollar amount; it does not matter that (even if the accounting firm could commit staff to the finalisation of the accounts) the profit cannot be ascertained with finality at the time of the notice; the information will be in the accountants' hands shortly and so the profit will be identifiable at a time close to the notice. It could even be said that the profit is presently identifiable if the information is somewhere within Company B; and the amount to be offset is already fixed in that it is controlled by the