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Re: marayatano post# 8855

Tuesday, 03/20/2012 9:56:52 PM

Tuesday, March 20, 2012 9:56:52 PM

Post# of 111251
"Yes, it is a change in ownership, but IRS allows 1 change of ownership every 2 years and still preserve tax attributes"

Subsection 382 I assume you are referring too.

I read parts of it and think I found the part you are reading but also found this right under.

" This subparagraph shall not apply to any equity structure
shift or transaction occurring on or after May 10, 1989."

That pretty much voided the subsection of 382 you were reading even if not, it is not as simple as you claim to do. A bunch of rules and not sure if Lehman can do it.....go figure..devil