Replies to post #8861 on Lehman Brothers Financial SA (LEHNQ)

[littledevils90210]

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

[yx88hc]

I failed to see how the quote you just provided:

If, during the 2-year period immediately following an ownership change to which this paragraph applies, an ownership change of the new loss corporation occurs, this paragraph shall not apply and the section 382 limitation with respect to the 2nd ownership change for any post-change year ending after the change date of the 2nd ownership change shall be zero.

leads to your earlier statement:

"IRS allows 1 change of ownership every 2 years and still preserve tax attributes."

Do you mind connecting the dots?