P Corporation owns all the stock of S1 and S2 Corporations. The corporations have filed consolidated tax

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P Corporation owns all the stock of S1 and S2 Corporations. The corporations have filed consolidated tax returns since their creation in Year 1. At the close of business on July 10 of Year 2, P sells all of its S2 stock. The group reports the following results:

Тахаble Incoте Group Member Year 1 Year 2 $32,000 $(18,000) (24,000) (28,000) P (8,000) 30,000a S1 S2 Consolidated taxable income (before NOL deduction) $38,000 $(70,000)

a $14,000 is attributable to January 1 through July 10 of Year 2, and $16,000 is attributable to July 11 through December 31 of Year 2.

b $32,000 + ($8,000) + $14,000 In what year(s) can the corporations deduct the Year 1 consolidated NOL? Assume that Year 1 is a post-2017 year.

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Federal Taxation 2021 Corporations, Partnerships, Estates & Trusts

ISBN: 9780135919460

34th Edition

Authors: Timothy J. Rupert, Kenneth E. Anderson, David S. Hulse

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