If Al really bought RPTN for the losses, he must be a real goober, unless of course, he plans to sell ethernet switching equipment.
Under the IRS code, the “value” of a net operating loss (NOL) is zero if the Continuity-of-Business requirement is not met.
Failure to meet the business-continuity requirement is fatal; the IRC section 382 limitation becomes zero. None of the pre-change losses can be used. The continuity test requires that either the historic business must continue, or a significant portion of the historic assets must be used. Where multiple lines of business are involved, continuation of one of the significant lines of business will meet the requirement under current regulations. Thus, discontinuing a loss line and using its losses against a continuing profitable line should be allowable. This continuity must be maintained for a period of two years after the change date.