Question
(You may use two pages to answer questions (h), (i) and (j) below). The Davis Corporation, a calendar year corporation, acquires all of the stock
(You may use two pages to answer questions (h), (i) and (j) below).
The Davis Corporation, a calendar year corporation, acquires all of the stock of Teledent Corporation, a calendar year corporation, in a "B" reorganization for $600,000 worth of its voting common stock. After the transaction, the former shareholders of Teledent own 20% of the outstanding Davis stock. Teledent has net operating loss carryovers of $1,000,000.
(h) Assume a 5% "long term tax exempt rate." What is the Sec. 382 limitation? Explain your answer.
(i) Assume that only 40% of the Sec. 382 Limitation is used in the following year. What happens to the excess?
(j) Assume that Teledent has a Net Unrealized Built In Gain of $200,000. In the next year after its acquisition, $40,000 of the NUBIG is recognized. Does this affect the Sec. 382 Limitation?
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