Pre-change subgroup attribute
(f) Pre-change subgroup attribute(1) Defined. A pre-change subgroup attribute of a loss subgroup is (i) Any net operating loss carryover described in paragraph (d)(1)(iii) of this section (relating to the definition of loss subgroup); and (ii) Any recognized built-in loss of the loss subgroup. (2) Example. The following example illustrates the principle of this paragraph (f):