On March 15,2013,Blue Corporation Purchased 10% of the Gold Corporation

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a.A qualified stock purchase occurs when one corporation acquires,in a taxable transaction,stock representing at least 80% of the total voting power and at least 80% of the value of another corporation within a 12-month period.For purposes of Blue Corporation,a qualified stock purchase occurs with the July 23,2014,purchase [90% = 40% (October 24,2013) + 25% (April 4,2014) + 25% (July 23,2014)].

b.The § 338 election must be made by the fifteenth day of the ninth month beginning after the month in which a qualified stock purchase occurs.Since Blue's qualified stock purchase date is July 23,2014,the election must be filed by April 15,2015.

On March 15,2013,Blue Corporation Purchased 10% of the Gold Corporation

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