Questions from Federal Taxation

Q: P Corporation owns all the stock of S1 and S2 Corporations.

P Corporation owns all the stock of S1 and S2 Corporations. The corporations have filed consolidated tax returns since their creation in Year 1. At the close of business on July 10 of Year 3, P sells...

Q: P Corporation owns all the stock of S Corporation, and P

P Corporation owns all the stock of S Corporation, and P and S file a consolidated tax return. On January 1 of Year 2, P creates T Corporation and acquires all of its stock. P, S, and T report the fol...

Q: P Corporation acquires all of S Corporation’s stock on January 1 of

P Corporation acquires all of S Corporation’s stock on January 1 of Year 2. In Year 1, the corporations were unrelated entities that filed separate returns. P and S report the follow...

Q: P Corporation owns all the stock of S1 and S2 Corporations,

P Corporation owns all the stock of S1 and S2 Corporations, and the group has filed consolidated tax returns on a calendar year basis for several years. In the current year (Year 1), S2 sells to S1 fo...

Q: Explain the conditions under which Sec. 751 has an impact on

Explain the conditions under which Sec. 751 has an impact on nonliquidating (current) distributions.

Q: P Corporation acquires all of S Corporation’s stock at the close of

P Corporation acquires all of S Corporation’s stock at the close of business on December 31 of Year 1. The corporations, which file on the calendar year, begin filing a consolidated...

Q: Bart, P’s sole shareholder, creates P on January 1 of

Bart, P’s sole shareholder, creates P on January 1 of Year 1. P purchases all of S1’s and S2’s stock on September 1 of Year 1, after both corporat...

Q: P Corporation owns 100% of S Corporation’s stock, and they

P Corporation owns 100% of S Corporation’s stock, and they have filed consolidated tax returns for several years. P also has owned 49% of T Corporation’s stock for 10 years. On December 31 of the curr...

Q: Mark Green and his brother Michael purchased land in Orlando, Florida

Mark Green and his brother Michael purchased land in Orlando, Florida many years ago. At that time, they began their investing as Green Brothers Partnership with capital they obtained from placing sec...

Q: P Corporation owns 100% of S Corporation’s stock, and S

P Corporation owns 100% of S Corporation’s stock, and S owns 100% of T Corporation’s stock. The three corporations have filed consolidated tax returns for several years. On January 1 of the current ye...