The Section 382 - Steptoe & Johnson
On January 1, 1991, L corporation is wholly owned by individual A. A has held all of the L stock since L's formation in 1985. L has a $200 NOL carryover from a previous year. On December 31, 1994, A sells all of his stock to B for $500 (the fair market value of L). At that time, the long-term tax-exempt rate for section 382 purposes is 5 percent. ................
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