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3.Corporation P acquired the stock of Corporation T for $30 Million from T shareholders. No Section 338 election was made. Corporation T has assets with

3.Corporation P acquired the stock of Corporation T for $30 Million from T shareholders. No Section 338 election was made. Corporation T has assets with a fair market value of $25 Million and an adjusted basis of $21 Million. Corporation T also has a net operating loss carryover of $20 Million. The federal long term tax exempt rate at the date of acquisition is 5%.

What is Ps basis in Ts assets and what is the annual limitation on the use of Ts net operating loss?

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