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Parent Corporation Owns 100% of the Stock of Subsidiary Corporation

question 30

Essay

Parent Corporation owns 100% of the stock of Subsidiary Corporation. The adjusted basis of its stock investment is $100,000. A plan of liquidation is adopted. Subsidiary distributes to Parent assets with a $325,000 FMV and a $275,000 adjusted basis. Subsidiary also distributes liabilities in the amount of $40,000. Subsidiary has a $150,000 E&P balance.
a)What is the amount and character of Subsidiary Corporation's recognized gain or loss on the distribution?
b)What is the amount and character of Parent Corporation's recognized gain or loss on the redemption of the Subsidiary stock?
c)What basis does Parent take in the assets?
d)What happens to parent Corporation's basis in the Subsidiary stock and to Subsidiary's tax attributes?

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Definitions:

Resonance Form

Alternative structures of a molecule that depict its electrons in different positions, illustrating delocalization within the molecule.

Line-Angle Formula

A shorthand representation of organic molecules where lines represent bonds and vertices represent carbon atoms, simplifying structural depiction.

Resonance Structure

Different Lewis structures representing the same molecule that differ only in the positions of the electrons, not the positions of the atoms.

Organic Molecule

A molecule of the kind typically found in living systems, often containing carbon atoms bonded to hydrogen, oxygen, or nitrogen.

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