Sixteen years ago, Biff, Buffy, and Buffy, Jr. organized Beach Wear Inc. (BWI) to sell beach wear throughout California. The sole class of common stock of BWI is owned by Buffy (60%) and her husband, Biff (20%), and Buffy, Jr. (20%). On December 1 of the tax year specified for the exam, BWI files an S election. As of December 31 of that same tax year, BWI's balance sheet includes the following:

Asset AB FMV

Accounts Receivable $ 0 $300,000

Payments Due Under

Installment Sale $450,000 $600,000

Machinery $ 0 $225,000

During the next tax year, BWI collected the accounts receivable receiving $300,000. BWI also collected the one of two payments still due on the installment sale of $300,000. BWI's taxable income for the same tax year is $900,000.

Same facts as above, except that BWI has a net operating loss for the year ended December 31 of the tax year before the year specified for the exam in the amount of $300,000.

a.

The NOL reduces the taxable income calculated as if the S Corporation were a C Corporation under 1374(d)(2)(A)(ii).

b.

The NOL reduces the recognized built-in gain of $375,000 by the $300,000 for purposes of the tax calculation.

c.

The NOL does not reduce the flow-through of the $375,000. Only the built-in gain tax reduces the flow-through of the $375,000.

d.

All of the above.