pre-change loss

(1)The term “pre-change loss” means— (A)any net operating loss carryforward of the old loss corporation to the taxable year ending with the ownership change or in which the change date occurs, and (B)the net operating loss of the old loss corporation for the taxable year in which the ownership change occurs to the extent such loss is allocable to the period in such year on or before the change date.

Source

26 USC § 382(d)(1)


Scoping language

For purposes of this section
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