The objective of the § 382 limitation is to restrict the use of tax carryover benefits to a hypothetical future income stream from the former loss corporation's assets,based on its stock value at the time of the reorganization.
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Q29: The so-called "anti-stuffing" rules are designed to
Q30: The continuity of interest and the continuity
Q31: Since the § 382 limitation purpose is
Q32: A 50 percentage point ownership shift evoking
Q33: To expedite requests for letter rulings on
Q35: A "Type E" reorganization has tax implications
Q36: Besides the statutory requirements,reorganizations must meet several
Q37: Since a "Type F" reorganization includes a
Q38: In the business purpose requirement for tax-free
Q39: With a divisive "Type D" reorganization,two corporations
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