Section 2518 of the internal revenue code

U.S. Code: Title 26 - INTERNAL REVENUE CODE - US Law
(2) TheInternalRevenueCode enacted on February 10, 1939, as amended, may be cited as theInternalRevenueCode of 1939”. (b) Publication. This Act shall be published as volume 68A ofthe United States Statutes at Large, with a comprehensive table of contents and an appendix; but without.

Valuation Considerations of Section 382... - Valuation Research
Section 382 oftheInternalRevenueCode generally requires a corporation to limit the amount of its income in future years that can be offset by historic losses, i.e., net operating loss (NOL) carryforwards and certain built-in losses, after a corporation has undergone an ownership change.