Sienna Company developed a specialized banking application software program that it licenses to various financial institutions through multiple-year agreements. On January 1, 2021, these licensing agreements have a fair value of $870,000 and represent Sienna's sole asset. Although Sienna currently has no liabilities, the company has a $150,000 net operating loss (NOL) carry-forward because of recent operating losses. On January 1, 2021, Paoli, Inc., acquired all of Sienna's voting stock for $1,100,000. Paol