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:

Net Income

The total earnings of a company after subtracting all expenses, including taxes, from its total revenues.

Purchased Goodwill

The premium paid over the fair value of identifiable net assets during the acquisition of a company, reflecting intangible assets like brand reputation or customer loyalty.

Net Income

The total profit of a company after all expenses, including taxes, interest, and operating costs, have been deducted from total revenue.

Dividends

Payments made by a corporation to its shareholders, typically from profits, as a distribution of earnings.