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

question 83

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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?


Definitions:

Alcoholism

A chronic disease characterized by uncontrolled drinking and a preoccupation with alcohol.

Gross Sales

The total amount of sales recorded before any deductions for returns, allowances, or discounts.

Sales Discounts

A reduction in the price of a product or service that is offered by the seller, often to prompt early payment or bulk purchases.

Sales Returns

Transactions involving the return of sold goods by customers, resulting in a reduction of revenue.

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