Senior, Ltd., acquires all of the stock of JuniorCo for $30 million at the beginning of year

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Senior, Ltd., acquires all of the stock of JuniorCo for $30 million at the beginning of year 1. The group immediately elects to file income tax returns on a consolidated basis. Senior’s operations generate a $50 million profit every year. In year 2, JuniorCo pays its parent a $9 million dividend. Operating results for JuniorCo are as follows.

 Tax Year                         Taxable Income

1 ………………..        $ 4 million

2 ………………..        12 million

3 ………………..        15 million

a. Compute Senior’s basis in the JuniorCo stock as of the end of years 1, 2, and 3.

b. Same as (a), except that JuniorCo’s tax year 2 produced a $6 million NOL.

c. Same as (a), except that JuniorCo’s tax year 2 produced a $40 million NOL.

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South Western Federal Taxation 2016 Corporations Partnerships Estates And Trusts

ISBN: 9781305399884

39th Edition

Authors: James Boyd, William Hoffman, Raabe, David Maloney, Young

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