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Ownership changes under the new Sec. 382 segregation rules.
In certain circumstances, loss corporations previously subject to a Sec. 382 limitation due to an ownership change may retroactively elect that the ownership change did not occur. On Oct. 4, 1993, the IRS issued final regulations relating to the Sec. 382 segregation rules. These regulations ...
February 1, 1994; The Tax Adviser

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