Section 45 Tax Attributes of New Target Corporation

• Library: Business Transitions 2009 Supp

A stock sale between two brothers was an ownership change under I.R.C. § 382, limiting the deductibility of the company’s net operating loss carryforwards. Garber Indus., Inc. v. Comm’r, 435 F.3d 555 (5^th Cir. 2006).