Leader has business assets worth $8 million and NOL carryovers of $1million expiring in 14 years and of $2 million expiring in 15 years, and 100 percent of Leaders stock is worth $10 million. If Leader sells its business assets without recognizing gain or loss, Leader can invest its $8 million liquid assets in US T-Bills earning 2.1% so that Leader can use its NOLs at the rate of $168,000 per year. The long-term tax-exempt rate is 1.71%. What will the the 382 limitation be if an ownership change occurs with respect to Leaders stock? Will Leader be able to utilize the NOLs before they expire?