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

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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:

Store Replenishment Collaboration

Collaborative efforts between retailers and suppliers to ensure that products are restocked efficiently and effectively, balancing inventory levels with consumer demand.

Forecasts

Predictions or estimates about future events, trends, or behaviors, typically based on historical data and analysis, used in planning and decision-making processes.

Customer Demand

The desire of purchasers, clients, or consumers for specific goods or services over a given time period.

Incentives

Motivational tools or rewards designed to influence the behavior of individuals or organizations towards desired outcomes.

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