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

question 83

Multiple Choice

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?

• A)0%
• B)50%
• C)75%
• D)80%

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Definitions:

Cross Bed Formation

The structures within sedimentary rocks that result from angled deposition due to wind or water currents, indicating the direction of flow.

Sediment Composition

The makeup or content of material particles that accumulate on the Earth's surface, which can range from organic matter to minerals and rocks.

Climate Change

Long-term significant changes in the temperature, precipitation, and patterns of weather across the globe, often attributed to human activities.

Iron Formation

A geological formation consisting of layers of iron minerals, often found as banded iron formations which are significant sources of iron ore.