Question
Winter Corporation owns 100% of Summer Corporation's single class of stock. Its adjusted basis for the stock is $300,000. After adopting a plan of liquidation,
Winter Corporation owns 100% of Summer
Corporation's single class of stock. Its adjusted basis for the stock is $300,000. After adopting a plan of liquidation, Summer distributes the following property to Winter: money, $70,000; LIFO inventory, $225,000 FMV; and equipment, $80,000 FMV. The inventory has a $145,000 adjusted basis. The equipment originally cost $280,000.Summer has claimed depreciation of $210,000 on the equipment. Summer has a $120,000 E&P balance and a $50,000 NOL carryover on the liquidation date.
Requirement a. What are the amount and character of Summer's recognized gain or loss when it makes the liquidating distributions?
Summer (Does not not recognize/Recognizes) the $____ gain realized on the distribution to Winter per (Sec. 331/332a./334b.1?337a.)
Requirement b. What are the amount and character of Winter's recognized gain or loss on its surrender of the Summer stock?
Winter (Does not recognize/Recognizes) the $____ gain realized on the distribution received per (Sec 331/332/334b.1/337a.)
Requirement c. What is Winter's basis in each noncash property?
Inventory:
Property:
Requirement d. What happens to Summer's E&P balance and NOL carryover following the liquidation?
Summer's E&P balance and NOL (Disappears per Sec 331/Disappears per Sec 381a/Carry over to Winter per Sec 331/Carry over to Winter per Sec 381a)
Requirement e. What happens to Winter's $300,000 basis in the Summer stock?
Winters basis for the stock (disappears/ carry over to Summer/is increased by the distribution amount/remains the same)
Step by Step Solution
There are 3 Steps involved in it
Step: 1
Get Instant Access with AI-Powered Solutions
See step-by-step solutions with expert insights and AI powered tools for academic success
Step: 2
Step: 3
Ace Your Homework with AI
Get the answers you need in no time with our AI-driven, step-by-step assistance
Get Started