Question
Murray Corporations stock is owned by about 1,000 shareholders, none of whom own more than 1% of the outstanding shares. Pursuant to a tender offer,
Murray Corporations stock is owned by about 1,000 shareholders, none of whom own more than 1% of the outstanding shares. Pursuant to a tender offer, Said purchased all the Murray stock for $7.5 million cash at the close of business on December 31, 2014. Before the acquisition, Said owned no Murray stock. Murray had incurred substantial NOLs, which totaled $1 million at the end of 2014. Murrays taxable income is expected to be $200,000 and $600,000, respectively, for 2015 and 2016. Assuming the long-term tax-exempt federal rate is 5% and Murray continues in the same trade or business, what amount of NOLs can Murray use in 2015 and/or 2016? What amount of NOLs and Sec. 382 limitation carryover to 2017?
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