Alan

has

always

owned

all

of

the

common

stock

of

Loser

Inc.;

Loser's

only

class

of

stock

outstanding.

Loser

operates

a

retail

store

that

has

been

losing

money

(although

it

broke

even

this

year)

and

has

a

total

of

$1

million

in

NOL

carryovers

expiring

in

part

during

the

next

10

to

15

years.

Unrelated

Player

operates

a

profitable

manufacturing

business

(which

earns

$500,000

this

year

after

the

alternative

transactions

described

below)

and

owns

a

substantial

amount

of

highly

appreciated

assets.

What

effect

does

each

of

the

following

transactions

have

on

Loser's

NOL

carryover?

a. Alan

contributes

sufficient

capital

to

Loser

so

that

Loser

can

buy

Player's

profitable

manufacturing

business,

all

of

Player's

assets.

b. Loser

sells

all

of

its

assets

to

X

and

uses

the

proceeds

to

buy

the

profitable

manufacturing

business

from

Player.

c.

Alan

has

always

owned

all

of

the

stock

of

Player.

Alan

causes

Player

to

merge

into

Loser.

d. Loser

acquires

the

stock

of

Player

from

an

unrelated

party

for

cash

and

causes