Dreyer Corporation purchased 5% of Willy Corporation's stock five years ago for $100,000. Dreyer then decides to purchase an additional 80% of the Willy stock for $1,000,000 on April 15 of the current year. On the acquisition date, Willy Corporation's liabilities are $150,000. A $300,000 tax liability is incurred by Willy on the Sec. 338 deemed sale. What is the total basis of Willy Corporation's
assets for Sec. 338 basis allocation purposes?
What will be an ideal response?
Grossed-up basis of recently purchased stock = $1,000,000 × [(100% - 5%)/80%] = $1,187,500.
Total grossed-up basis of stock = $1,187,500 (grossed-up basis of recently purchased stock) + $100,000 (basis of nonrecently purchased stock) = $1,287,500.
Adjusted grossed-up basis (allocated to individual assets) = $1,287,500 + $150,000 nontax liabilities + $300,000 taxes = $1,737,500. This basis is allocated to the individual assets by using the residual method.
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What will be an ideal response?
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