(Answered) Taxation: Angela owns all the stock of A- B- and P Corporations

Here's a simple taxation problem that I need help with......thanks for getting me started!;============================================;Angela owns all the stock of A, B, and P Corporations. P has owned all the stock of S1 Corporation for six years. The P-S1 affiliated group has filed a consolidated tax return in each of these six years using the calendar year as its tax year. On July 10 of the current year (a non-leap year), Angela sells her entire stock investment in A, which uses the calendar year as its tax year. No change takes place in Angela's ownership of B stock during the tax year. At the close of business on November 25 of this year, S1 purchases 90% of the common stock and 80% of the nonconvertible, nonvoting preferred stock (measured by value) of S2 Corporation. A, P, S1, and S2 are domestic corporations that do not retain any special filing status.;Which corporations are included in the affiliated group? In the controlled group?;What income is included in the various tax returns?;How is the allocation of the income between tax years made if the books are not closed on the sale or acquisition dates?;If no special allocations are made, what portion of the reduced tax rate benefits of Sec. 11 (b) can be claimed in the current year by the affiliated group? In future years?;A partial list of resources includes;IRC Sec 1504;IRC Sec. 1563;Reg. Sec. 1.1502-76;Temp. Reg. Sec. 1.165-2T
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Taxation: Angela owns all the stock of A- B- and P Corporations


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Dec 18, 2020





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