SRLY and Sec. $382$ Loss Limitations. P Corporation owns $100\%$ of S Corporation's

stock, and they have filed consolidated tax returns for several years. P also has owned

$49\%$ of T Corporation's stock for $10$ years. On December $31$ of the current year $($Year $1),$

P purchases the other $51\%$ of T$\text{'}$s stock for $$510,000$ cash. T has $$160,000$ of NOLs it is

carrying over on that date. In Year $2,$ the corporations report taxable profits as follows:

P$,$ $$400,000$; S$,$ $$250,000$; and T$,$ $$90,000.$ Assume that the long$-$term tax$-$exempt federal

interest rate is $5\%$ and that Year $1$ is a post$-2017$ year.

a$.$ Determine the amount of T$\text{'}$s NOLs the group can deduct for its Year $2$ consolidated

taxable income.

b$.$ Assume the same facts as in Part a except P purchases $45\%$ of T$\text{'}$s stock for $$450,000$

on December $31$ of Year $1.$ Determine the amount of T$\text{'}$s NOLs the group can deduct

for its Year $2$ consolidated taxable income.