The following advertisement appeared in a financial journal:

$17 MILLION CASH WITH

ADDITIONAL CASH AVAILABLE

$105 MM TAX LOSS GOOD THROUGH 2031

CAPITAL GROUP, INC.

NASDAQ listed w/300 shareholders

WANTS TO ACQUIRE COMPANY

with Net Before Tax Audited Earnings of $7MM to $10MM

Exceptional Opportunity and Participation for Sellers and 

Existing Management. Contact: Albert M. Zlotnick or Ross P.

Lederer, Tel: (000)-000-0000 and Fax: (000)-000-0000.

Required: Prepare a memorandum explaining the tax advantages that would accrue to the Capital Group if it acquired the stock or assets of a profitable corporation in a nontaxable reorganization or a taxable transaction. Would the advantages be the same if a profitable corporation acquired Capital? In addition, explain any tax law provisions that might restrict the use of these loss carryovers.