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On September 30 of the current year, Silver Oak Corporation files for bankruptcy. At the time, it estimates that the total FMV of its assets

On September 30 of the current year, Silver Oak Corporation files for bankruptcy. At the time, it estimates that the total FMV of its assets is $550,000, whereas the total amount of its outstanding debt amounts to $760,000. Silver Oak Corporation has been engaged in the resale of tax preparation and tax research-related books and software for several years.

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.Requirement a. At the time of the bankruptcy, Silver Oak is owned by Rafael, who purchased the stock from an investor for $270,000 several years ago. Rafael

is single. What are the amount and character of the loss sustained by Rafael upon Silver Oak's bankruptcy?

Does the stock qualify as Sec. 1244 stock?

Rafael will realize

in the amount of

Requirements

a.

At the time of the bankruptcy, ilver Oak is owned by Rafael, who purchased the stock from an investor for $270,000 several years ago. Rafael is single. What are the amount and character of the loss sustained by

Rafael upon Silver Oak's bankruptcy?

b.

How would your answer to part a change if Rafael originally organized Silver Oak Corporation, capitalizing it with$270,000 of cash and assuming Silver Oak qualifies as a small business corporation?

c.

How would your answer to Part a change if Rafael were a corporation instead of an individual?

d.

How would your answer to Part b change if Rafael were a corporation instead of an individual?

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