The Section 382 - Steptoe

No ownership change of the loss group results since D is the only shareholder that has increased her ownership in the continuing loss group during the testing period, and the increase is only 10 percent. See Treas. Reg. § 1.1502-92(b)(3)(iii) Ex. (2). Any NOL's belonging to P as it enters the group will be subject to the SRLY rules. ................
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