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Corporation P acquired the stock of Corporation T for $40 Million from T shareholders. No Section 338 election was made. Corporation T has assets with
Corporation P acquired the stock of Corporation T for $40 Million from T shareholders. No Section 338 election was made. Corporation T has assets with a fair market value of $37 Million and an adjusted basis of $32 Million. Corporation T also has a net operating loss carryover of $10 Million. The federal long-term tax-exempt rate at the date of acquisition is 3%.
A) What is Ps basis in Ts assets and what is the annual limitation on the use of Ts net operating loss?
B) Briefly explain the current rules for using corporate net operating losses.
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