Rachel has been going over her tax lecture notes and is trying to understand the concept of liquidations. She has concluded a corporation is always required to recognize gains and losses on the distribution of property in a complete liquidation.

Is she correct? Why or why not? Are there any exceptions which may apply?

Josh liquidated his furniture business and distributed some of the assets to his half-brother, Sam.

Can Josh take any losses on this transaction? Why or why not?

Does liquidation unfairly penalize shareholders? Should shareholders be able to recoup their investment? Why or why not?

Liquidations favor parent companies over subsidiaries. Why or why not?

Some feel the bankruptcy laws favor corporations over individuals. Do you agree? Why or why not?

Josh believes stock attribution rules impact liquidations by firms. Is he correct? Why or why not?

Josh anticipates he will have substantial earnings this year and wants to lower his taxes. He decides to liquidate his business in order to take a loss. Is this ethical? Why or why not?

When properties transferred by a shareholder in a Section 351 transaction have a net built-in loss (aggregate fair market value less than aggregate basis), the basis step-down rule must be applied. Discuss the relevant of the built-in loss limitation given the enactment of the basis step-down rule.