$BH,$ which is publicly$-$traded, is a conglomerate. It wants to distribute one of its divisions, called Geico, to its

shareholders. BH distributes Geico stock pro rata to its shareholders. BH Corporation had a net operating loss $($NOL$)$

of $$10m$ at the time of the distribution.

What are the federal income tax results of this distribution? Would your answer change if $BH$ had purchased Geico

just two years ago?

What result if$,$ six months after the distribution, Allstate Corp. acquires $100\%$ of the stock of Geico for $$200m?$

Would your answer to a$.$ change if$,80\%$ of Geico's assets constituted U$.$S$.$ government bonds and cash?