Corporate Liquidations, Taxable Acquisition Transactions, homework help

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“Corporate Liquidations, Taxable Acquisition
Transactions, and Nontaxable Reorganizations” Please respond to the
following:

  • From
    the e-Activity, evaluate the appropriateness of the techniques used and
    the common issues pursued by the IRS in corporate liquidations and
    dissolutions. Create an argument to defend the client if the IRS pursues
    the assignment of income doctrine or the clear reflection of income
    doctrine on a cash-basis corporation, as reflected in the Examining
    Officers Guide (EOG).

e-Activity: Go to the Tax Almanac Website, located
at http://www.taxalmanac.org/index.php/Tax_Research_Resources,
or use the Internet and Strayer databases to research Section 336 of the IRC,
Treasury Regulations 1.336, and related judicial decisions. Focus on the
appropriateness of the techniques used and the common issues pursued by the IRS
in corporate liquidations and dissolutions. Be prepared to discuss.

  • IRC
    Section 338 allows a deemed sale election generating immediate taxation to
    the target corporation and a stepped-up or stepped-down basis to the price
    paid by the acquiring corporation for the target corporation stock plus
    liabilities on the deemed sale. Examine at least one (1) benefit of a Section
    IRC 338 liquidation election for a target corporation. Create a situation
    which demonstrates a favorable IRC Section 338 liquidation election for a
    target corporation.

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