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Mariano Owns All of Alpha Corporation, Which Owns 100% of Beta

question 83

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Mariano owns all of Alpha Corporation, which owns 100% of Beta Corporation's single class of stock. On January 1, Alpha and Beta Corporations report a consolidated NOL carryover from prior years. What is the maximum percentage of Alpha Corporation's single class of stock that Mariano can sell to a single shareholder without triggering the Sec. 382 loss limitation?


Definitions:

Annually Balanced Budget

A fiscal strategy or policy where government revenues are planned to match expenditures within a single year, aiming to prevent budget deficits.

Tax Revenues

Tax revenues refer to the income that is collected by the government from individuals and businesses, primarily through taxes such as income tax, sales tax, and property tax.

Government Spending

Government spending encompasses all the expenditures of government agencies and departments, including investments, consumption, and transfers, aimed at achieving economic and social objectives.

Cyclically Balanced Budget

A budget philosophy calling for budget deficits during recessions to be financed by budget surpluses during expansions.

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