The Parent consolidated group includes SubTwo, which was acquired as part of a 382 ownership change. SubTwo brought with it to the group a large NOL…

The Parent consolidated group includes SubTwo, which was acquired as part of a § 382 ownership change. SubTwo brought with it to the group a large NOL carryforward, $2.5 million of which is available this year under the SRLYrules due to SubTwo’s positive contribution to the group’s taxable income. The § 382 limitation with respect to SubTwo is $400,000. How much of SubTwo’s NOL can be used this year to reduce consolidated taxable income?

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