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Pacific, Inc. is a calendar-year S corporation that was a C corporation from 1990-2021 when it made its first S corporation election effective for January

Pacific, Inc. is a calendar-year S corporation that was a C corporation from 1990-2021 when it made its first S corporation election effective for January 1, 2022.  At the end of 2022, Pacific does not have any C corporation earnings and profits.  Pacific does not have any loss carryforwards from C years. Pacific has always used the accrual method of tax accounting.   Assume that Section 1375 does not apply.   Information about Pacific for 2022 is as follows:

  • Net unrealized built-in gain at beginning of year                                                      $ 1,000,000
  • Recognized built-in gains for the year                                                                             250,000
  • Recognized built-in losses for the year                                                                              50,000
  • Taxable income as if a C corp. taking into account the above items                            150,000

Required: 

A.       Compute Pacific's entity-level tax for 2022 (assuming it is 2023), if any, taking account of Section 1374.  

B.       What carry overs, if any, exist?  EXPLAIN.

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