Questions from Federal Taxation

Q: The stock of Quail Corporation is held as follows: 85%

The stock of Quail Corporation is held as follows: 85% by Pheasant Corporation and 15% by Gisela, an individual. Quail Corporation is liquidated in December of the current year pursuant to a plan adop...

Q: Blush Corporation owns long-term bonds (basis of $1

Blush Corporation owns long-term bonds (basis of $1.3 million) of its subsidiary, Brass Corporation, that were acquired at a discount. Upon liquidation of Brass pursuant to § 332, Blush receives a dis...

Q: LO.S Park Corporation distributes its shoe manufacturing line of business

LO.S Park Corporation distributes its shoe manufacturing line of business to the newly created ShoeBiz Corporation in a transaction qualifying as a '"Type D" spin-off reorganization. Before the distri...

Q: Penguin LLC operates a large apparel store with several employees and substantial

Penguin LLC operates a large apparel store with several employees and substantial debt. Each LLC member is active in the business and receives compensation from the LLC. The LLC invests it5 excess cas...

Q: The Parent consolidated group reports the following results for the tax year

The Parent consolidated group reports the following results for the tax year. a. What is the group's consolidated taxable income and consolidated tax liability' b. If the Parent group has consented...

Q: Spinone Corporation directs its sole shareholder, James, to exchange all

Spinone Corporation directs its sole shareholder, James, to exchange all of his common stock valued at $200,000 (basis of $50,000) for $100,000 of common stock, $70,000 of preferred stock, and $30,000...

Q: Ryce contributes non-depreciable property with an adjusted basis of $

Ryce contributes non-depreciable property with an adjusted basis of $60,000 and a fair market value of $95,000 to the Montgomery Partnership in exchange for a one-half interest in profits and capital....

Q: Oudine the process by which a consolidated group computes its Federal taxable

Oudine the process by which a consolidated group computes its Federal taxable income. Your description should match the approach taken in Exhibit 8.2.

Q: Mini Corporation brought a $7 million NOL carryforward into the Mucho

Mini Corporation brought a $7 million NOL carryforward into the Mucho Group of corporations that elected to file on a consolidated basis as of the beginning of this year. Combined results for the year...

Q: The consolidated return Regulations employ the "SRLY" rules to limit

The consolidated return Regulations employ the "SRLY" rules to limit the losses a parent can claim with respect to a newly acquired subsidiary. Explain the tax policy behind the SRLY rules. Describe h...