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In Most Situations, a Target Subsidiary Has Some Assets That

question 39

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In most situations, a target subsidiary has some assets that have appreciated in value (i.e., fair market value exceeds the asset's basis), and other assets where the value is less than the asset's basis.In such case, the acquiring corporation, desiring the highest basis possible for the assets, might first purchase the appreciated property, then purchase the subsidiary's stock, and then liquidate the subsidiary under § 332.By so doing, the acquiring corporation might violate the Code's "consistency" provision.


Definitions:

Limbic System

A complex system of nerves and networks in the brain, involved in emotions and drives, such as fear, pleasure, and anger.

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Memories strongly influenced by emotions, which can alter the recall's intensity and accuracy.

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A sensory function provided by the olfactory system, allowing individuals to perceive and differentiate odors.

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Supportive cells in the nervous system that play key roles in maintaining homeostasis, forming myelin, and providing support and protection for neurons.

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