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Tuesday, March 20, 2012 11:18:21 PM
First, lets talk about the first ownership change before you get to the second one. I dont see anywhere in the IRC that states you can just disregard the Lehman equity 100%,75%,50%,20%,10% or anything. The snip bit posted does not address that. It frankly does not mean anything. After the first merger or ownership change, OLD LEHMAN EQUITY will be addressed already
I am not sure what youa re trying to point out in IRC 382? If you are saying old equity (one big share) or whatever can be negated, I disagree and nowhere in IRC 382 supports that.
I am out of post. Bummer...go figure..devil
Re-read the BOLD portion of your reply to me.
That is in regards to the first ownership change. As an example: Disregarding equity is the first ownership change. As long as there is no more ownership changes within 2 years, the tax attributes are preserved.
imo
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