J.S. Bachman owns 100% of Legato Corporations stock and has a $350,000 basis in his stock. On
Question:
Staccato Corporation wishes to purchase, for cash, 80% of Legatos stock from Mr. Bachman and then make a Sec. 338 election. Determine the following amounts resulting from the transaction and Sec. 338 election: Grossed-up basis (G), aggregated deemed sale price (ADSP), total gain (loss) recognized, tax liability, adjusted grossed-up basis (AGUB), basis of each asset after allocating the AGUB, and gain recognized by Mr. Bachman. Assume a 34% corporate tax rate, and determine the required amounts in each of the following independent situations.
a. Staccato pays $491,200 for the Legato stock.
b. Staccato pays $600,000 for the Legato stock.
c. Staccato pays $470,000 for the Legato stock.
d. Staccato pays $670,000 for the Legato stock.
A Corporation is a legal form of business that is separate from its owner. In other words, a corporation is a business or organization formed by a group of people, and its right and liabilities separate from those of the individuals involved. It may...
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Federal Taxation 2016 Comprehensive
ISBN: 9780134104379
29th Edition
Authors: Thomas R. Pope, Timothy J. Rupert, Kenneth E. Anderson