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In 2022, TJ Smoothie decides it will expand into the cold pressed juice market. The shareholders become aware of a struggling cold pressed juice company
In 2022, TJ Smoothie decides it will expand into the cold pressed juice market. The shareholders become aware of a struggling cold pressed juice company (Tin & Juice) that has $100,000 of NOLs, assets worth $20,000 and liabilities of $10,000 (assume all assets are business assets). Tin and Juice is owned by two equal shareholders (Dr. J and S. Dogg). Dr. J and S. Dogg are looking cut their losses and sell the business. On January 1, 2022, TJ Smoothie purchases all of Dr. J's stock and half of S. Dogg's stock for $12,000, resulting in TJ Smoothie owning 75% and S. Dogg retaining 25% of Tin & Juice. In February 2023, TJ closes the Tin & Juice store, but still sell pre-bottled juice in their TJ Smoothie shops. For purposes of this problem assume the long-term tax-exempt rate is 5 percent. a) If TJ Smoothie's taxable income is break even in 2022 and $1,000 in 2023, to what extent can TJ Smoothie deduct Tin & Juice's NOLs in both years? b) Would your answer in (a) change if TJ Smoothie did not continue to sell pre-bottled juice in February 2023
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