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, 2013. Before the acquisition, Said owned no Murray stock. Murray had incurred substantial NOLs, which at the end of 2013 totaled $1 million. Murray's taxable income is expected to be $200,000 and $600,000, respectively, for 2014 and 2015. 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 2014 and/or 2015? What amount of NOLs and Sec. 382 limitation carryover to 2016?
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Federal Taxation 2015 Corporations Partnerships Estates & Trusts

ISBN: 9780133822144

28th Edition

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

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