Blitzer Corporation Is the Parent Corporation of a 10-Member Group

question 79

Essay

Blitzer Corporation is the parent corporation of a 10-member group that has filed consolidated tax returns for a number of years. Last year, the group sold all the stock of Wolf Corporation to Jerry Jensen. This year, Wolf Corporation reported a $300,000 NOL. Wolf's taxable income while a group member averaged $200,000 annually for the past five years but is expected to be only $50,000 next year due to start-up costs that will be incurred with the introduction of a new product line. Profits are expected to increase in each succeeding year. What issues should Blitzer have considered when trying to value Wolf's NOL prior to its sale? What tax issues should Wolf now consider when deciding how to use its NOL?

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Definitions:

Equal Employment Opportunity Commission

A federal agency in the United States charged with enforcing laws against workplace discrimination.

Federal Communications Commission

A government agency in the United States responsible for regulating interstate and international communications by radio, television, wire, satellite, and cable.

Industrial Regulation

Governmental regulation of industries to correct market failures, protect consumers, and preserve competitive markets.

Social Regulation

Rules and policies designed to correct market failures that affect people's health, safety, welfare, and social wellbeing.