03 Feb Parent Corporation owns 100% of Subsidiary Corpora
Parent Corporation owns 100% of Subsidiary Corporation’s single class of stock. Its adjusted basis for the stock is $175,000. After adopting a plan of liquidation, Subsidiary distributes the following property to Parent: money, $20,000; LIFO inventory, $200,000 FMV; and equipment, $150,000 FMV. The inventory has a $125,000 adjusted basis. The equipment originally cost $280,000. Subsidiary has claimed depreciation of $160,000 on the equipment. Subsidiary has a $150,000 E&P balance and a $40,000 NOL carryover on the liquidation date. a. What are the amount and character of Subsidiary’s recognized gain or loss when it makes the liquidating distributions? b. What are the amount and character of Parent’s recognized gain or loss on its surrender of the Subsidiary stock? c. What is Parent’s basis in each noncash property? d. What happens to Subsidiary’s E&P balance and NOL carryover following the liquidation? e. What happens to Parent’s $175,000 basis in the Subsidiary stock?