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The Application of the § 382 Limitation to Credits Requires

question 134

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The application of the § 382 limitation to credits requires determining the income tax reduction benefit when applying the § 382 limitation to deductions.


Definitions:

Contractual Rights

Legal entitlements derived from agreements between parties that are enforceable by law.

Creditor Beneficiary

A third party that benefits from a contract made between two other parties, especially when the contract's purpose is to repay a debt or obligation.

Donee Beneficiary

A third party who benefits from a contract between two other parties, especially in cases where the contract is intended as a gift to the third party.

Second-party Beneficiary

A person or group that benefits from a contract, despite not being a direct party to that contract.

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