Question
Under section 332, at the time of liquidation, Cargo Corporation -E&P of $500,000- had the following assets and liabilities: Cash $175,000 Marketable Securities - FMV
Under section 332, at the time of liquidation, Cargo Corporation -E&P of $500,000- had the following assets and liabilities:
Cash $175,000
Marketable Securities - FMV of $230,000, basis of $250,000 -
Unimproved land - FMV of $600,000, basis of $300,000 -
Unsecured payable $50,000
Mortgage on the unimproved land $270,000
Cargo Corporation also had a net operating loss carryover of $45,000. Wright Corporation acquited all of the stock of Cargo Corp. 7 years ago for $160,000.
a. How much gain or loss will Cargo Corp. recognize in the liquidating distribution of its assets and liabilities to Wright Corp.?
b.How much gain or loss will Wright Corp. recognize in the liquidation of Cargo Corp.?
c.What basis will Wrigh Corp. have in the marketable securities and unimproved land it receives in the liquidation?
d.What happens to Cargo's E&P and net operation loss carryover?
Wright | Cargo | |
REALIZED | Parent | Subsidiary |
FMV Received | ||
- Basis Given Up | ||
Tax Gain Realized | ||
RECOGNIZED & DEFERRED | ||
Tax Gain Realized | ||
- Deferred Gain under |
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