The Section 382

Example 4. L is a loss corporation. Individual A owns 80 percent and corporation P owns 20 percent of L. P purchases all the L stock owned by A. L undergoes an ownership change as a result of P's purchase. L will be subject to both a separately computed section 382 limitation and the SRLY rules. See Treas. Reg. § 1.1502-94(b)(4) Ex. (3). ................
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