36. LO.6 Miguel Allred is going to purchase either the stock or the assets of Jewel Corporation. All of the Jewel stock is owned by Charley. Miguel and Charley agree that Jewel is worth $700,000. The tax basis for Jewel’s assets is $500,000.

Write a letter to Miguel, advising him on whether he should negotiate to purchase the stock or the assets. Prepare a memo for the tax research file on this matter.

Miguel’s address is 100 Aspen Green, Chattanooga, TN 37403.