Chip and Dale Are Each 50% Owners of Tree Corporation

question 26

Essay

Chip and Dale are each 50% owners of Tree Corporation, a holding company. They have each held their stock since the company was formed five years ago. Tree's money is invested almost entirely in stocks, bonds, rental real estate, and land. All of the stocks are traded on the New York Stock Exchange except for 1,000 shares of Conifer Corporation stock. Conifer is privately held by 50 individuals. Last year, Conifer reported about $2 million in net income. During a meeting with Chip and Dale, you discover that they plan to liquidate Tree Corporation as soon as possible to avoid the personal holding company tax. What tax issues should Chip and Dale consider with respect to this liquidation?

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Definitions:

Rising Prices

An economic situation characterized by a general increase in the prices of goods and services.

Dollar-Value LIFO

An inventory valuation method that uses the dollar value of inventory rather than the physical count of goods, adjusting for inflation.

Current Cost

The cost to replace an asset or settle a liability at the current market rate, as opposed to its historical purchase price or book value.

Average Cost

A calculation that divides the total cost of goods available for sale by the total number of units available for sale, determining the cost per unit.