A corporate reorganization involving the transfer of the assets of one or more corporations to another corporation often raises questions regarding the ability of the transferee corporation to carry back postacquisition net operating losses under Internal Revenue Code section 172 to the preacquisition taxable years of the transferor corporations. This note more fully examines the provisions and significance of Revenue Ruling 75-561 regarding F reorganizations. The discussion is divided into three parts: (1) a brief historical overview of the case law that gave rise to Revenue Ruling 75-561; (2) an examination of the provisions of the ruling; and (3) an examination of some of the questions and problems the ruling leaves unanswered.
Thomas N. Lawson,
Use of Multicorporate F Reorganizations to Carry Back Net Operating Losses: Rev. Rul. 75-561, 1975-2 Cum. Bull. 129,
56 Neb. L. Rev. 173
Available at: http://digitalcommons.unl.edu/nlr/vol56/iss1/6