I have full faith in the colleague I asked this about, you would be impressed by his credentials. I tried reading your first link and it seemed that it was geared towards a tax attorney, so I believe there were certain assumptions that the reader already knew that Section 382 applied to a 50% change in ownership, but had to watch for pitfalls where the 50% change could by triggered unknowingly.

I believe Section 382 is geared towards a controlling interest in a corp - hence if there is a 50% increase in ownership that acquiring entity must have control.

Of course all of this is a moot point if all of our expectations are met regarding revenues and profits. If things go according to how many of us here believe, PTSC will be out of NOL`s by next year.