In your opinion, you said that you believe an ownership change occurred, and that shareholders owned the company assets.... read what the professionals say about "ownership change says"....., especially when a company is a "Loss Company", or not a "Loss company"....In order for your posts to be accurate, you must engage a professional tax attorney to verify your assertion....IMO, you are wrong, because WMI was not a "Loss Company", and owned 100 % of the stock which they abandoned in the GSA proceedings....the link presented is complicated to read, but it is by professionals in the business...Lodas