step one.42. 34 isn’t then followed or perhaps is unavailable, lent money would-be commingled along with other cash in you to definitely membership. In such issues, tracing/connecting is actually problematic since the money is fungible and you can taxpayers are unable to track the amount of money to identifiable uses. But not, this kind of activities, taxpayers are entitled to apply new versatile approach to tracing/linking explained inside ¶step one.38.