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:

Hole Alignment

The accuracy with which holes are positioned in relation to each other or to specified datums.

Spring Loaded Mechanism

A mechanical device incorporating a spring that applies a force or allows for a specific action once triggered or released.

Cotter Pins

A fastener used to prevent a wheel or other part from sliding off the axle upon which it is riding.

Taper Pins

Cylindrical metal fasteners that have a slight cone shape, allowing them to securely fit into tapered holes for alignment purposes.