Loss corporations entities that have a nol or built in gain or loss are eligible to use a nol subject to section 382. If the section 382 limitation for any post change year exceeds the taxable income of the new loss corporation for such year which was offset by pre change losses the section 382 limitation for the next post change year shall be increased by the amount of such excess. A loss corporation is a firm that can use tax attributes such as net operating loss nol to deduct their taxable income.
fcra section 623
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