Hi,

My assigment is the following: Prepare a tax memo on these issues (no more than four pages), to the tax partner on this engagement, Robert Holder.You need to read Sections 382 and 108 and the related regulations (Regs. Sec. 1.1502-28) to develop your solution.You must show how your plan to reduce the tax attributes resulting from the Cancellation of Debt income (see the ordering rules and elections that may be made).In addition to searching the primary tax sources, you should search the web as many accounting and law firms have written articles about this topic.You should also consult IRS form 982 and the instructions.You should discuss the Code, Regulations, Court Cases, Rulings, etc., that will support your strategy to advise and assist Mr. Harris accomplish his goals, if possible.Remember to search for court cases and IRS administrative pronouncements.

I already researched the sections, but I am still confused as the final solution tax.

Thanks