The Section 382 - Steptoe & Johnson

Section 382 applies to L1 even though more than 50 percent of the L1 stock ownership did not change (only 40.8 percent (51 percent x 80 percent) changed). See Treas. Reg. § 1.1502-92(b)(2) Ex. (1). By contrast, if A sold only 49 percent of the L stock to C, and thereafter B sold his L1 stock to D, no ownership change would result under this ... ................
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