Scenario 1: NOL & Change in Ownership
A sole proprietorship generates a large NOL of ($120,000).
Prior Year NOL carryforward available: $0.
The following year, the business incorporates as a C-Corporation, and the original owner retains majority ownership.
Wages in the year of the NOL and the following year: $0.
Interest and Dividend Income (both years): $1,000.
Itemized Deductions (both years): $15,000.
Allowable deduction for self-employment tax in the year of the NOL: $9,500.
Questions:
How much of the NOL can be deducted in the year it was generated?
Can the NOL carryforward be used by the C-Corporation after the change in ownership? If so, are there limitations?
Research relevant IRS rules and code sections (e.g., Section 382) on NOLs and ownership changes.