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Perry Corporation purchased 10 percent of Target Corporation's stock for $35,000 in 2020. On March 1, 2024, Perry purchased an additional 80 percent of Target's
Perry Corporation purchased 10 percent of Target Corporation's stock for $35,000 in 2020. On March 1, 2024, Perry purchased an additional 80 percent of Target's stock for $200,000. At that time, Target's identifiable assets had a fair market value of $300,000 and an adjusted basis of $240,000. Target also had liabilities of $60,000 and an accumulated earnings and profits balance of $147,000. a. What is the acquisition date for purposes of making a basis adjustment election under Internal Revenue Code 338? b. What is the date by which Perry must file a 338 election? c. Assuming a 338 election is timely made, what is the deemed sale price of Target's assets? d. What tax liability results from the deemed sale of assets? e. Assuming the tax liability in part d is not included in Target's $60,000 of liabilities, what is the amount of the adjusted grossed-up basis that is allocated to the assets? f. What amount of goodwill results from the application of the 338 adjustment to Target's assets? g. What is Target Corporation's balance in accumulated earnings and profits immediately after the effective date of the 338 election
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