RE: Was there an ownership change, so NOL limitation? Nathan

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RE: Was there an ownership change, so NOL limitation? Nathan

posted on Mar 25, 2006 08:22AM

More to the point, here`s the critical reference -

``(1) In general

There is an ownership change if, immediately after any owner shift involving a 5-percent shareholder or any equity structure shift—

(A) the percentage of the stock of the loss corporation owned by 1 or more 5-percent shareholders has increased by more than 50 percentage points, over

(B) the lowest percentage of stock of the loss corporation (or any predecessor corporation) owned by such shareholders at any time during the testing period. ``

Since there is no change by more than 50 percentage points, there is no change in ownership.

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