Liabilities (nonrecourse mortgage plus unsecured liabilities) | $700 |
Taxes Payable | 300 |
Total | 1,000 |
Grossed-up basis | $2,000 |
Total liabilities | 1,000 |
AGUB | 3,000 |
Asset class | Asset | Fair market value |
---|---|---|
I | Cash | * $200 |
II | Portfolio of actively traded securities | 300 |
III | Accounts receivable | 600 |
IV | Inventory | 300 |
V | Building | 800 |
V | Land | 200 |
V | Investment in T1 | 450 |
Total | 2,850 | |
*Amount. |
Building | $800 |
Land | 200 |
Investment in T1 | 450 |
Code of Federal Regulations
124
|
|
Total | 1,450 |
General Liabilities | $100 |
Taxes Payable | 20 |
Total | 120 |
Grossed-up basis of T1 Stock | $ 500 |
Liabilities | 120 |
AGUB | 620 |
Asset class | Asset | Fair market value |
---|---|---|
I | Cash | *$50 |
IV | Inventory | 200 |
VI | Patent | 350 |
Total | 600 | |
* Amount. |
Grossed-up basis of recently purchased stock as determined under § 1.338-5(c) ($1,600 × (1−.2)/.8) | $1,600 |
Basis of nonrecently purchased stock | 100 |
Liabilities | 1,000 |
AGUB | 2,700 |
Grossed-up basis of recently purchased stock as determined under § 1.338-5(c) ($1,600 × (1−.2)/.8) | $1,600 |
Basis of nonrecently purchased stock as if the gain recognition election under § 1.338-5(d)(2) had been made ($1,600 × .2/(1−.2)) | 400 |
Liabilities | 1,000 |
Total | 3,000 |
Class | Asset | Original allocation | Finalallocation |
---|---|---|---|
I | Cash | $200 | $200 |
II | Portfolio of actively traded securities | 300 | *268 |
III | Accounts receivable | 600 | 536 |
IV | Inventory | 300 | 268 |
V | Building | 800 | 714 |
V | Land | 200 | 178 |
V | Investment in T1 | 450 | 402 |
VII | Goodwill and going concern value | 150 | 134 |
Total | 3,000 | 2,700 | |
* All numbers rounded for convenience. |