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ParentCo purchased all the stock of ChildCo on January 2, Year 2, and the two companies filed consolidated returns for Year 2 and thereafter. Both

ParentCo purchased all the stock of ChildCo on January 2, Year 2, and the two companies filed consolidated returns for Year 2 and thereafter. Both entities were incorporated in Year 1. Taxable income computations for the members include the following. Neither group member incurred any capital gain or loss transactions during these years, nor did they make any charitable contributions. Assume no 382 limit applies.

ParentCos

ChildCos Taxable

Consolidated

Year

Taxable Income

Income

Taxable Income

Year 1

$100,000

($ 75,000)

N/A

Year 2

$100,000

($ 40,000)

$60,000

Year 3

$100,000

$ 10,000

?

Year 4

$100,000

$125,000

?

To what extent can ChildCos Year 1 losses be used by the group in Year 4?

a.

$135,000

b.

$125,000

c.

$75,000

d.

$10,000

e.

$0

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