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The "SRLY" and § 382 Limitation Rules for Federal Consolidated

Question 149

Essay

The "SRLY" and § 382 limitation rules for Federal consolidated tax returns are designed to keep corporations from "trafficking" their net operating losses. These rules are restrictive and somewhat complex. Explain why these rules exist and how they interact if both apply in the same tax year.

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The separate return limitation rule SRLY...

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