No need for explanations. Only attempt if you will answer all posted questions.

1.Which types of reorganizations (acquisitive, divisive, and other) permit the carryover of tax attributes from a target or transferor corporation to an acquiring or transferee corporation?

A.Target corporation's tax attributes carryover to the acquiring corporation in Type A, C, acquisitive D, F and G reorganizations.

B.Target corporation's tax attributes carryover to the acquiring corporation in all types of reorganziations, acquisitive, divisive, and others.

C.Target corporation's tax attributes carryover to the acquiring corporation in Type A, C, and D reorganizations only.

D.Target corporation's tax attributes carryover to the acquiring corporation in divisive D, F and G reorganizations only.

2.Does the receipt of a favorable advance ruling provide the taxpayer with a guarantee that the IRS will follow the ruling if it audits the completed transaction?

A.Yes, always. Once the IRS provides a ruling, the statute of limitations for the transaction is closed and cannot be reopened for the tax year in question.

B.Yes, most of the time. However, if the IRS concludes that the transaction is materially different from what the taxpayer had previously proposed and what the IRS approved in the private letter ruling, the IRS may re-review the facts.

C.No. Once the taxpayer receives a favorable advance ruling from the IRS, the IRS can at any point revoke their ruling even if the revocation is not due to a law change or new facts regarding the case being brought before them.

D.Yes. However, the IRS can change their ruling if they later discover they are losing a large tax flows resulting from the ruling when the tax attributes provide tax savings to the corporation.

3.Alpha Corporation purchased for cash a 5% interest in Theta Corporation stock. After buying the stock and examining Theta's books, Alpha's management wants to make a tender offer to acquire the remaining Theta stock in exchange for Alpha voting stock. What problems might be encountered in structuring the acquisition as a nontaxable reorganization?

A.If the transactions are more than 6 months apart, the transactions generally will be considered independent events. If the time between the two transactions is 6 months or less, the IRS generally will collapse the stock purchase and the tender offer and find that the "solely-for-voting-stock" requirement has not been met, thereby rendering the transaction fully taxable.

B.If the transactions are more than 12 months apart, the transactions generally will be considered independent events. If the time between the two transactions is 12 months or less, the IRS generally will collapse the stock purchase and the tender offer and find that the "solely-for-voting-stock" requirement has not been met, thereby rendering the transaction fully taxable.

C.If the transactions are more than 12 months apart, the transactions generally will not be considered independent events. If the time between the two transactions is 12 months or less, the IRS generally will collapse the stock purchase and the tender offer and find that the "solely-for-voting-stock" requirement has been met, thereby rendering the transaction fully taxable.

D.After reviewing the transactions, the IRS may decide that the acquisition cannot move forward at all.