Murray Corporations stock is owned by about 1,000 shareholders, none of whom own more than 1% of

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Murray Corporation’s stock is owned by about 1,000 shareholders, none of whom own more than 1% of the outstanding shares. Pursuant to a tender offer, Said, an individual investor, purchased all the Murray stock for $7.5 million cash at the close of business on December 31, 2019. Before the acquisition, Said owned no Murray stock. Murray had incurred a $1 million NOL in 2018 but no NOLs after that date. Murray’s taxable income is expected to be $200,000 in 2020. Assuming the long term tax-exempt federal rate is 5% and Murray continues in the same trade or business, what amount of NOLs can Murray use in 2020? What is Murray’s NOL carryover to 2021, and what is the Sec. 382 limitation for 2021?

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Federal Taxation 2021 Corporations, Partnerships, Estates & Trusts

ISBN: 9780135919460

34th Edition

Authors: Timothy J. Rupert, Kenneth E. Anderson, David S. Hulse

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