Apparently my memory isn't that great.   🤣

That was the Dave I was referring to (in my opinion, if he asserts a position, it is almost certainly correct).  However, it I guess it was a different Dave that pointed out some sound logic in this thread in post #28.

https://www.taxprotalk.com/forums/viewtopic.php?f=8&t=6838

But I haven't had a chance to process the counter-arguement in post #29, so that could affect how to look at things.