Question
Parent Corporation owns 85% of the common stock and 100% of the preferred stock of Subsidiary Corporation. The common stock and preferred stock have adjusted
Parent Corporation owns 85% of the common stock and 100% of the preferred stock of Subsidiary Corporation. The common stock and preferred stock have adjusted bases of $500,000 and $200,000, respectively, to Parent. Subsidiary adopts a plan of liquidation on July 3 of the current year, when its assets have a $1 million FMV. Liabilities on that date amount to $850,000. On November 9, Subsidiary pays off its creditors and distributes $150,000 to Parent with respect to its preferred stock. No cash remains to be paid to Parent with respect to the remaining $50,000 of its liquidation preference for the preferred stock, or with respect to any of the common stock. In each of Subsidiary's tax years, less than 10% of its gross income has been passiveincome. What are the amount and character of Parent's loss on the preferred stock? The common stock?
A partial list of research sources is
IRC Secs. 165(g)(3) and 332(a)
Reg. Sec. 1.332-2(b)
Spaulding Bakeries, Inc.,27 T.C. 684 (1957)
H. K. Porter Co., Inc.,87 T.C. 689 (1986)
please use the sources above and, if any, include additional sources you use to ans the questions.
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