Murray Corporation's stock is owned by about 1,000 shareholders, none of whom own more than 1% of

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Murray Corporation's stock is owned by about 1,000 shareholders, none of whom own more than 1% of the outstanding shares. Pursuant to a tender offer, Said purchased all the Murray stock for $7.5 million cash at the close of business on December 31, 2012. Before the acquisition, Said owned no Murray stock. Murray had incurred substantial NOLs, which at the end of 2012 totaled $1 million. Murray's taxable income is expected to be $200,000 and $600,000, respectively, for 2013 and 2014. Assuming the long-term tax-exempt federal rate is 5% and Murray continues in the same trade or business, what amount of NOLs can Murray use in 2013 and/or 2014? What amount of NOLs and Sec. 382 limitation carryover to 2015?
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Federal Taxation 2014 Comprehensive

ISBN: 9780133438598

27th Edition

Authors: Timothy J. Rupert, Thomas R. Pope, Kenneth E. Anderson

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