Perry Corporation purchased 10 percent of Target Corporation's stock for $35,000 in 2016. On March 1, 2019,

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Perry Corporation purchased 10 percent of Target Corporation's stock for $35,000 in 2016. On March 1, 2019, Perry purchased an additional 80 percent of Target’s stock for

$200,000. At that time, Target’s identifiable assets had a fair market value of $300,000 and an adjusted basis of $240,000. Target also had liabilities of $60,000.

a. What is the acquisition date for purposes of making a Code Sec. 338 election? By what date must Perry file a Code Sec. 338 election?

b. Assuming that a Code Sec. 338 election is made, what is the deemed sale price of Target's assets?

c. What is the amount of the adjusted grossed-up basis that is allocated to Target's assets, assuming that a tax liability of $15,000 resulted from the deemed sale of assets?

d. What amount of goodwill results from the allocation of basis to Target's assets?

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CCH Federal Taxation Basic Principles 2020

ISBN: 9780808051787

2020 Edition

Authors: Ephraim P. Smith, Philip J. Harmelink, James R. Hasselback

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