Instant Download PDF Prentice Halls Federal Taxation 2014 Comprehensive 27th Edition Rupert Test Bank Full Chapter

Prentice Halls Federal Taxation 2014
Comprehensive 27th Edition Rupert

Test Bank
Go to download the full and correct content document:
https://testbankfan.com/product/prentice-halls-federal-taxation-2014-comprehensive-2
7th-edition-rupert-test-bank/
More products digital (pdf, epub, mobi) instant
download maybe you interests ...
Prentice Halls Federal Taxation 2014 Comprehensive 27th

Edition Rupert Solutions Manual
https://testbankfan.com/product/prentice-halls-federal-
taxation-2014-comprehensive-27th-edition-rupert-solutions-manual/
Prentice Halls Federal Taxation 2014 Individuals 27th

Edition Rupert Test Bank
taxation-2014-individuals-27th-edition-rupert-test-bank/
Prentice Halls Federal Taxation 2014 Individuals 27th

Edition Rupert Solutions Manual
taxation-2014-individuals-27th-edition-rupert-solutions-manual/
Prentice Halls Federal Taxation 2014 Corporations

Partnerships Estates and Trusts 27th Edition Anderson
Test Bank
taxation-2014-corporations-partnerships-estates-and-trusts-27th-
edition-anderson-test-bank/
Prentice Halls Federal Taxation 2014 Corporations
Partnerships Estates and Trusts 27th Edition Anderson
Solutions Manual
taxation-2014-corporations-partnerships-estates-and-trusts-27th-
edition-anderson-solutions-manual/

Edition Pope Test Bank
taxation-2015-comprehensive-28th-edition-pope-test-bank/



Edition Pope Solutions Manual
taxation-2013-comprehensive-26th-edition-pope-solutions-manual/
Prentice Hall's Federal Taxation 2014 Corporations, 27e
Chapter C8 Consolidated Tax Returns
1) To be an affiliated group, the parent corporation must directly own at least 80% of another group
member.
Answer: TRUE
Page Ref.: C:8-2
Objective: 1
2) A Canadian subsidiary cannot file as part of the consolidated group with its U.S. parent.
Answer: FALSE
Page Ref.: C:8-5 through C:8-6
Objective: 1
3) Brother-sister controlled groups can elect to file a consolidated tax return.

Answer: FALSE
Page Ref.: C:8-4
Objective: 1
4) An advantage of filing a consolidated return is that losses of one affiliated group member may be offset
against the taxable income of other group members in the same tax year.
Answer: TRUE
Page Ref.: C:8-36
Objective: 8
5) The election to file a consolidated return is made annually.

Answer: FALSE
Page Ref.: C:8-5
Objective: 2
6) A separate return year is a corporation's tax year for which it files a separate tax return or files a
consolidated tax return with another affiliated group.
Answer: TRUE
Page Ref.: C:8-5
Objective: 2
7) P and S are members of an affiliated group that has filed consolidated tax returns for a number of
years. The sale of inventory by P that was acquired from S in an intercompany transaction outside the
affiliated group triggers the recognition of gain by S.
Answer: TRUE
Page Ref.: C:8-18
Objective: 2
8) Intercompany dividends and undistributed subsidiary earnings do not create temporary differences
for affiliated companies filing a consolidated return.
Answer: TRUE
Page Ref.: C:8-21
Objective: 4
1
Copyright © 2014 Pearson Education, Inc.
9) A member's portion of a consolidated NOL may be carried back against that member's taxable income
from the preceding two separate return years.
Answer: TRUE
Page Ref.: C:8-30
Objective: 6
10) The treatment of capital loss carrybacks and carryovers is similar to NOLs.
Answer: TRUE
Page Ref.: C:8-28
Objective: 5
11) The IRS can attempt to collect taxes owed on a consolidated return from any of the members of the
consolidated group.
Answer: TRUE
Page Ref.: C:8-39
Objective: 9
12) Intercompany sales between members of an affiliated group filing separate returns cause deferred tax
assets to be recognized by both buyer and seller.
Answer: FALSE
Page Ref.: C:8-10
Objective: 4
13) Identify which of the following statements is true.

A) To be part of an affiliated group, a corporation must be at least 80% directly owned by another group
member.
B) Only common stock is considered when determining if the 80% ownership test is met for affiliated
group eligibility.
C) An affiliated group electing to file a consolidated return may be composed of as few as two
corporations.
D) All of the above are false.
Answer: C
Page Ref.: C:8-2 and C:8-3
Objective: 1
14) Which of the following corporations is an includible corporation for purposes of filing a consolidated
tax return?
A) insurance companies
B) S corporations
C) car manufacturing corporation
D) foreign corporations
Answer: C
Page Ref.: C:8-3
Objective: 1
2
15) Diana Corporation owns stock of Tomika Corporation. For Diana and Tomika to qualify for the filing
of consolidated returns, at least what percentage of Tomika's total voting power and total value of stock
must be directly owned by Diana?
A)
Total voting power Total Value of stock
51% 51%
B)
51% 80%
C)
80% 51%
D)
80% 80%
Answer: D
Page Ref.: C:8-3
Objective: 1
16) Ajak Corporation owns 85% of the single class of Utech Corporation stock. Utech Corporation owns
35% of Tech Corporation. Ajak Corporation also owns 50% of Tech Corporation, and Tech Corporation
owns 75% of Baxter Corporation.
A) Ajak, Tech, Utech, and Baxter Corporations are an affiliated group.
B) Ajak, Tech, and Baxter Corporations are an affiliated group.
C) Ajak, Tech, and Utech Corporations are an affiliated group.
D) None of the above are correct.
Answer: C
Page Ref.: C:8-3
Objective: 1
17) Which of the following corporations is entitled to join in a consolidated tax return without making a
special election?
A) corporations exempt from tax under Sec. 501
B) real estate investment trusts
C) closely held corporations
D) foreign corporations
Answer: C
Page Ref.: C:8-3
Objective: 1
3
A) If 100% of the stock of two corporations is owned by the same individual, the two corporations are
eligible to file a consolidated return.
B) The check-the-box regulations permit partnership and LLCs to elect C corporation tax treatment.
C) A group of corporations that meets the parent-subsidiary controlled group requirements is always
eligible to file a consolidated return.
Answer: B
Page Ref.: C:8-4
Objective: 1

A) When a new corporation joins an affiliated group, all of its income and expense items for the tax year,
including the acquisition date, must be allocated between the separate tax return and consolidated tax
return that are to be filed based on the number of days included in each of the two tax years.
B) A consolidated return election may be revoked after 5 years.
C) All members of a consolidated group must use the same tax year.
Answer: C
Objective: 3

A) Corporations that join in a consolidated return must adopt the same tax year as the parent corporation.
B) Permission to discontinue the filing of consolidated tax returns is sometimes granted by the IRS.
C) Additional administrative costs may be incurred when filing a consolidated tax return.
D) All of the above are true.
Answer: D
Objective: 2

A) A corporation may be required to file a separate return and file with an affiliated group in the same
calendar year.
B) When a corporation joins in filing a consolidated return, taxable income of the member is combined
with other members' taxable income prior to any adjustments.
C) If a corporation becomes a member of an affiliated group within the first thirty days of the
corporation's tax year, the corporation can elect not to file a short-period tax return.
Answer: A
Objective: 3
4
22) Cardinal and Bluebird Corporations both use a calendar year as their tax year. At the close of business
on June 30, Cardinal Corporation buys all of Bluebird Corporation's stock. If the two corporations file a
consolidated return and both corporations earn their income evenly throughout the year, what portion of
Cardinal's income will be included in the consolidated return? (Assume all months have 30 days.)
A) 100%
B) 50%
C) 0%
D) none of the above
Answer: A
Page Ref.: C:8-5; Example C:8-6
Objective: 2
23) Cardinal and Bluebird Corporations both use a calendar year as their tax year. At the close of business
on June 30, Cardinal Corporation buys all of Bluebird Corporation's stock. If the two corporations file a
consolidated return and both corporations earn their income evenly throughout the year, what portion of
Bluebird's income will be included in the consolidated return? (Assume all months have 30 days.)
A) 100%
B) 50%
C) 0%
Answer: B
Objective: 2
24) Parent Corporation owns all of the stock of Richards and Smith Corporations on January 1. The three
corporations have filed consolidated tax returns for a number of calendar years. Parent sells all of the
stock of Richards Corporation on June 1. Parent purchases all of the stock of Taylor Corporation on
September 1. Parent sells all of the stock of Smith Corporation on November 1. When does the affiliated
group terminate?
A) June 1
B) September 1
C) November 1
D) The original affiliated group does not terminate.
Answer: D
Page Ref.: C:8-5
Objective: 2
5
25) Alto and Bass Corporations have filed consolidated tax returns for several calendar years. At the close
of business on September 30, Alto Corporation sells all of the Bass Corporation stock. What portion of
Alto's and Bass's income for the current year will be included in the consolidated return, assuming its
income is earned evenly throughout the year and all months have 30 days?
A)
Alto Bass
100% 100%
B)
Alto Bass
100% 75%
C)
Alto Bass
75% 75%

Answer: B
Page Ref.: C:8-5
Objective: 2
26) Which of the following statements is incorrect with respect to the consolidated alternative minimum
tax?
A) The starting point for the consolidated alternative minimum taxable income computation is
consolidated taxable income before the NOL deduction.
B) The difference between the consolidated ACE amount and the consolidated preadjustment AMTI is an
adjustment to consolidated taxable income in arriving at AMTI.
C) Each corporation is permitted its own $40,000 statutory exemption.
D) If the consolidated tentative minimum tax is smaller than the consolidated regular tax, there is no
alternative minimum tax liability.
Answer: C
Page Ref.: C:8-24
Objective: 5

A) The corporate AMT is determined on a separate return basis and then consolidated.
B) All corporations filing consolidated tax returns are subject to the AMT.
C) Alternative minimum tax payments from prior consolidated return years that are attributable to
timing or permanent differences can be carried over by the affiliated group and claimed as a credit on
current or future consolidated returns.
Answer: C
Page Ref.: C:8-24
Objective: 5
6
28) Which of the following statements is incorrect with respect to the consolidated alternative minimum
tax?
A) A separate alternative minimum taxable income computation is made for each individual group
member. These amounts are then totaled to arrive at consolidated alternative minimum taxable income.
B) Positive adjustments that are made with respect to one group member can be offset by negative
adjustments that are made with respect to another group member in computing consolidated alternative
minimum taxable income.
C) The affiliated group's alternative minimum tax payment is available as a credit against its regular tax
amount in future tax years.
D) The estimated tax payment rules apply to the alternative minimum tax.
Answer: A
Page Ref.: C:8-24
Objective: 5
29) Which of the following statements is true?

A) A consolidated group determines its general business credit on a consolidated basis.
B) The general business credit can be carried back 3 years and forward 15 years.
C) The general business credit can be carried forward indefinitely.
D) The general business credit can not be carried forward or backward.
Answer: A
Page Ref.: C:8-25
Objective: 5
30) The Alpha-Beta affiliated group has a consolidated regular tax amount of $52,000 and a tentative
minimum tax amount of $50,000 in the current year. The maximum general business credit that can be
used on the consolidated return is
A) $2,000.
B) $6,750.
C) $50,000.
Answer: A
Explanation: A) The general business credit that can be used equals the group's net income tax ($52,000)
minus the larger of (1) tentative minimum tax ($50,000), or (2) 25% of net income tax in excess of $25,000
($6,750) or $2,000 ($52,000 - $50,000).
Objective: 5
31) Identify which of the following statements is false.

A) A corresponding item includes the income, gain, deduction, or loss amount reported by the buyer
from an intercompany transaction, or from property acquired in an intercompany transaction.
B) Affiliated groups of corporations filing a consolidated tax return are not eligible for the small
corporation exemption from the corporate alternative minimum tax.
C) An intercompany transaction generally results in the selling member and buying member in a
property transaction being treated as divisions of a single corporation.
D) Intercompany dividends and undistributed subsidiary earnings do not create temporary differences
for affiliated companies filing a consolidated return.
Answer: B
Page Ref.: C:8-24
Objective: 5
7
A) Unused general business credit carryforwards, which originate in a consolidated return year, are
absorbed in a FIFO manner, beginning with the earliest ending tax year.
B) An intercompany transaction is a transaction that takes place between two corporations that are
members of the same affiliated group immediately after the transaction.
C) An intercompany item includes income reported by the seller on the providing of services by one
group member to another group member and the gain/loss reported by the seller on the sale of property
to another group member.
Answer: C
Objective: 4
33) Ajax and Brindel Corporations have filed consolidated returns for several calendar years. Ajax
acquires land for $60,000 on January 1 of last year. On September 1 of this year, Ajax sells the land to
Brindel for $90,000. The basis and holding period for the land acquired by Brindel are:
A)
Basis Holding Period Begins On
$60,000 January 2 of last year
B)
$90,000 January 2 of last year
C)
$90,000 September 2 of this year

Answer: C
Page Ref.: C:8-10
Objective: 4
34) Which of the following events is an intercompany transaction?

A) a capital contribution
B) accrual of interest on a loan made by one group member to another group member; both group
members use the accrual method of accounting
C) dividend payment received from a subsidiary corporation to its parent corporation; the subsidiary
corporation is not an includible corporation
D) a parent corporation's sale of stock of a subsidiary corporation to a nonmember of the group
Answer: B
Page Ref.: C:8-10
Objective: 5
8
35) Subsidiary Corporation purchases a used machine from Parent Corporation in an intercompany
transaction. Which of the following events is a corresponding event for the intercompany transaction?
A) the purchasing group member depreciating the machine
B) the purchasing group member selling the machine for cash to a nonmember of the group
C) the departure of the purchasing group member from the affiliated group when its stock is sold to a
nonmember of the group
D) All of the above are recognition events.
Answer: D
Objective: 4
36) Which of the following events is an intercompany transaction that requires the deferral and later
recognition of income?
A) accrual of rentals on a lease of real property owned by one group member that is used by another
group member; both group members use the accrual method of accounting
B) cash dividend payment from a subsidiary corporation to its parent corporation
C) sale of inventory from a subsidiary corporation to its parent corporation
D) None of the above transactions require the deferral and later recognition of income.
Answer: C
Page Ref.: C:8-9
Objective: 4

A) Inventory sales between group members are an example of an intercompany transaction.
B) The basis to the purchasing member of property acquired in an intercompany transaction is the
amount of cash paid to the selling member.
C) The holding period for property acquired in an intercompany transaction begins when the
corresponding item is reported.
D) In general, buyers and sellers engaging in an intercompany transaction are treated as separate entities.
Answer: C
Objective: 4

A) The basic accounting method elections that are used by the seller in intercompany transactions do not
override the intercompany transaction rules.
B) P and S are members of an affiliated group that has filed consolidated tax returns for a number of
years. The sale of inventory by P, which was acquired from S in an intercompany transaction, outside the
affiliated group triggers the restoration of gain by S.
C) Last year, P, S, and T Corporations have filed consolidated tax returns for a number of years. Last year
P Corporation sold land (a Sec. 1231 asset) to T at a $75,000 profit. The gain was deferred by P in last
year's consolidated tax return. P sold the T stock to Mike on June 1 of this year. The stock sale will require
P to report in its income the gain that was deferred on the land sale.
Answer: D
Objective: 3
9
39) Parent Corporation sells land (a capital asset) to Subsidiary Corporation in an intercompany
transaction, realizing a $25,000 gain. Subsidiary uses the land for five years in its trade or business before
selling the land to a nonmember of the group in a cash sale in which a $50,000 gain is realized. Which
statement is correct?
A) A $25,000 capital gain is included in consolidated taxable income when Parent sells the land to
Subsidiary Corporation. A $50,000 Sec. 1231 gain is included in consolidated taxable income when
Subsidiary sells the land.
B) A $25,000 capital gain and a $50,000 Sec. 1231 gain are included in consolidated taxable income when
C) A $75,000 Sec. 1231 gain ($25,000 from Parent and $50,000 from Subsidiary) is included in consolidated
taxable income in the year Subsidiary sells the land (assuming no recapture of previously deducted Sec.
1231 losses must occur).
D) None of the above are correct.
Answer: C
Explanation: C) The recomputed gain is $75,000 of Sec. 1231 gain. $50,000 of gain is reported by
Subsidiary. $25,000 is reported by Parent. Both Sec. 1231 gains are reported in the year of Subsidiary's
sale. The $25,000 amount reported by Parent is a restoration that reflects the fact that $25,000 was
included in Parent's separate taxable income in the year of the original sale to Subsidiary, which was
deferred when determining the group's consolidated taxable income.
Page Ref.: C:8-12
Objective: 4
40) Apple Corporation and Banana Corporation file consolidated returns. In January 2007, Apple sold
Banana property with a basis of $120,000 for its fair value of $150,000. Banana sold the property to an
unrelated party in April 2008 for $200,000. What amount of gain should be reported for these transactions
in the consolidated returns for 2011 and 2012?
A)
2007 2008
$30,000 $50,000
B)
2007 2008
$0 $50,000
C)
2007 2008
$30,000 $80,000
D)
2007 2008
$0 $80,000
Answer: D
Page Ref.: C:8-12
Objective: 4
10
41) Parent Corporation sells land (a capital asset) to Subsidiary Corporation in an intercompany
transaction, recognizing a $25,000 gain. Subsidiary holds the land as an investment for five years before
selling the land to a nonmember of the group on an installment basis in a sale in which a $50,000 gain is
realized. The sales proceeds are collectible in four equal installments with an appropriate interest amount
being charged to the purchaser. Which statement is correct?
A) A $25,000 capital gain is included in consolidated taxable income when Parent sells the land to
Subsidiary Corporation. A $50,000 capital gain is included in consolidated taxable income when
B) A $25,000 capital gain from Parent and a $50,000 capital gain from Subsidiary are included in
consolidated taxable income when Subsidiary sells the land.
C) The $25,000 capital gain from Parent and $50,000 capital gain from Subsidiary are included ratably in
consolidated taxable income, commencing in the year the first installment is received.
D) None of the above are correct
Answer: D
Explanation: D) The recomputed gain is $75,000 of capital gain. $15,000 ($75,000/5) of the recomputed
gain is recognized as each installment is collected. $10,000 of this gain is reported by Subsidiary and
$5,000 by Parent as each installment is collected. The $25,000 amount reported by Parent is a restoration
that reflects the fact that $25,000 was included in Parent's separate taxable income in the year of the
original sale to Subsidiary, which was deferred when determining the group's consolidated taxable
income.
Objective: 4
42) Parent and Subsidiary Corporations have filed calendar-year consolidated tax returns for several
years. Parent Corporation uses the cash method of accounting while Subsidiary Corporation uses the
accrual method of accounting. If Parent lends Subsidiary money,
A) the interest expense is deductible when accrued.
B) the interest expense and interest income may be reported in different consolidated return years.
C) the interest income is reported when the interest expense is accrued by Subsidiary.
D) the interest expense deduction is taken when Parent reports the interest income.
Answer: C
Objective: 4

A) P Corporation receives a dividend from its 100%-owned subsidiary corporation S. P and S have filed
consolidated tax returns for a number of years. The dividend payment is out of S's earnings and profits
and reduces P's investment in S. The dividend is an intercompany transaction and excluded from P's
gross income.
B) The consolidated dividends-received deduction percentage for dividends received by one affiliated
group member from another affiliated group member is always 100%.
C) The dividends-received deduction claimed when a $50,000 dividend is received from a 100%-owned
nonconsolidated life insurance company is $35,000 (ignoring any dividends-received deduction
limitations).
Answer: A
Page Ref.: C:8-21
Objective: 4
11
A) A shareholder corporation that receives a nondividend distribution from an affiliated group member
is not required to recognize a gain when the distribution amount exceeds the shareholder's basis in the
distributing corporation's stock.
B) The dividends-received deduction limitation for dividends received by members of an affiliated group
from nonmembers is applied to the separate taxable income of each group member.
C) The dividends-received deduction cannot be taken in full on a consolidated return if the deduction
amount creates or increases a consolidated NOL.
Answer: A
Page Ref.: C:8-21
Objective: 4

A) The charitable contribution deduction is calculated on a separate return basis for each group member,
and the separate company deductions of the individual group members are totaled to arrive at the
consolidated deduction.
B) An affiliated group member cannot carry over any unused charitable contribution deduction from a
consolidated return year to a separate return year if the member leaves the group prior to the end of the
current consolidated return year.
C) Charitable contributions, which cannot be deducted in a consolidated return due to the 10% deduction
limitation, can be carried forward indefinitely by the affiliated group.
Answer: D
Page Ref.: C:8-19
Objective: 5

A) The basic dividends-received deduction rules generally do not apply to the calculation of the
consolidated dividends-received deduction.
B) A member of an affiliated group can elect to carry back its own separate return losses from a
consolidated return year to one of its earlier profitable separate return years.
C) A consolidated NOL is computed in part by including the consolidated capital gain in taxable income.
Answer: C
Objective: 6
47) Which of the following intercompany transactions creates temporary book/tax differences when a
parent corporation owns 100% of a subsidiary's stock and the companies file a consolidated return?
A) intercompany dividends
B) undistributed subsidiary earnings
C) intercompany sale
D) None of the above items create temporary differences.
Answer: D
Page Ref.: C:8-39
Objective: 10
12
48) Which of the following statements is true?
A) The definition of an affiliated group is the same for purposes of calculating the U.S. production
activities deduction as it is for filing a consolidated return.
B) The consolidated charitable contributions deduction is limited to 10% of adjusted consolidated taxable
income, without regard to the consolidated DRD, consolidated NOL carrybacks, consolidated capital loss
carrybacks, and consolidated charitable contributions deduction.
C) The definition of an affiliated group for purposes of the U.S. production activities deduction uses a
60% ownership threshold.
D) All of the above are true statements.
Answer: B
Objective: 5
49) Parent and Subsidiary Corporations form an affiliated group. Last year, the initial year of operation,
Parent and Subsidiary filed separate returns. This year, the group files a consolidated tax return. The
results for last year and the current year are:
Taxable Income
Last Current
Parent ($10,000) $50,000
Subsidiary 30,000 (25,000)
How much of Subsidiary's loss can be carried back to last year?

A) $0
B) $20,000
C) $25,000
Answer: A
Objective: 6
50) Parent and Subsidiary Corporations form an affiliated group. Last year, the initial year of operation,
Parent and Subsidiary filed separate returns. This year. the group files a consolidated return.
Taxable Income
Last Current
Parent ($16,000) $20,000
Subsidiary 10,000 (21,000)
How much of the Subsidiary loss can be carried back to last year?
A) $0
B) $1,000
C) $10,000
Answer: B
Objective: 6
13
A) The parent corporation may elect that the affiliated group use its NOL as a carryforward only.
B) A portion of a consolidated NOL can be carried back or forward to a separate return year of an
individual group member.
C) The entire consolidated NOL may be available as a carryback or a carryover to a separate return year
of one of the members of an affiliated group.
Answer: D
Objective: 6
52) Mako and Snufco Corporations are affiliated and have filed consolidated returns for the past three
years. Mako acquired 100% of Zebco stock on January 1 of last year, the date of Zebco's formation. Mako,
Snufco, and Zebco, who have filed consolidated returns for last year and the current year, report the
following taxable incomes.
Taxable Income Taxable Income

Corporation
Last year Current year
Mako $18,000 $ 12,000
Snufco 9,000 8,000
Zebco (25,000) (35,000)
CTI $ 2,000 ($15,000)
The $15,000 consolidated NOL reported in the current year

A) cannot be carried back.
B) can be carried back three years ago only.
C) can be carried back to last year and the remainder, if any, carried forward to subsequent years.
D) can only be used in future years.
Answer: C
Explanation: C) The loss can be used to offset the income of Mako and Snufco.
Objective: 6
14
53) Pants and Skirt Corporations are affiliated and have filed consolidated tax returns for the past three
years. Pants acquires 100% of Zipper stock on January 1 of this year. Zipper Corporation filed separate
returns previously. Pants, Skirt, and Zipper filed a consolidated return for the current year and reported
the following taxable incomes:

Corporation
Pants $18,000 $ 12,000
Skirt 9,000 8,000
Zipper 7,000 (29,000)
CTI $34,000 ($ 9,000)
The $9,000 consolidated NOL reported in the current year

A) can offset taxable income of Pants and Skirt Corporations from last year.
B) can offset Zipper Corporation separate return taxable income only from last year.
C) can be used only as a carryover to the future.
D) can offset Zipper Corporation separate return taxable income from last year and then be carried
forward to offset the affiliated group's subsequent taxable income.
Answer: D
Objective: 6

A) An affiliated group member's allocated share of an NOL from a consolidated return year may not be
available as a carryback to a separate return year of the common parent corporation.
B) If a corporation ceases to be a member of an affiliated group, the corporation is entitled to carry
forward its share of the consolidated NOL even if the NOL could be used in full on the consolidated
return for the year of cessation.
C) The SRLY (separate return limitation year) rules are designed to prevent the affiliated group from
offsetting its current year taxable income by purchasing corporations having NOL carryovers in order to
use their NOLs.
Answer: C
Objective: 6

A) An affiliated group member incurring an NOL in a separate return year that is available as a carryback
or carryforward to a consolidated return year is subject to a limit on the use of the NOL when the loss
year is designated a separate return limitation year (SRLY).
B) A consolidated NOL may be carried back one year and carried forward twenty years.
C) An NOL incurred in a separate return limitation year by the corporation that is the common parent
corporation for the group in the carryover year is subject to the SRLY limitation.
Answer: A
Page Ref.: C:8-30
Objective: 6
15
56) Key and Glass Corporations were organized last year. They became an affiliated group and filed
separate tax returns. This year, the corporations begin filing a consolidated tax return. Key and Glass
report the following results:
Income (loss) Income (loss)

Consolidated
Key ($10,000) $40,000
Glass 30,000 (15,000)
Which of the following statements is not correct?

A) Key's last year NOL cannot offset Glass's last year profits.
B) Key's last year NOL cannot offset this year's consolidated taxable income.
C) Key's current year income must first be offset by Glass's current year loss.
D) Glass cannot carry its current year loss back against last year's income.
Answer: B
Explanation: B) Key can offset its last year NOL against the current year consolidated taxable income
($25,000).
Page Ref.: C:8-30
Objective: 6
57) Jackson and Tanker Corporations are members of an affiliated group. The two corporations have been
affiliated since they were formed last year. Both corporations have always used a calendar year as their
tax year. Tanker, the subsidiary, has a separate return year NOL of $14,000 from last year. Jackson
Corporation has a separate return year NOL of $16,000 from last year. Commencing this year, the two
corporations filed a consolidated tax return. The NOLs can be carried over
A) to a consolidated return year and both are SRLY (separate return limitation year) losses.
B) to a consolidated return year and Tanker's loss is a SRLY loss.
C) to a consolidated return year without limit.
D) to a consolidated return year and Jackson's loss is a SRLY loss.
Answer: C
Explanation: C) Since the corporations were affiliated since inception, the SRLY loss limitation does not
apply.
Page Ref.: C:8-31
Objective: 6

A) A built-in deduction accrues in a separate return year, but is not recognized in a consolidated return
year.
B) Section 382 adopts a single-entity approach in determining ownership changes.
C) The 50-percentage-point minimum stock ownership change that triggers the Sec. 382 loss limitation
rules will not occur in acquisitive transactions involving a group of corporations filing consolidated
returns.
Answer: B
Page Ref.: C:8-33
Objective: 6
16
59) Blue and Gold Corporations are members of the Blue-Gold affiliated group, which filed a
consolidated tax return for last year, reporting a $200,000 consolidated NOL. Small taxable income
amounts were reported by Blue and Gold in separate tax returns filed in years prior to last year. Early in
the current year, 100% of Blue's stock is purchased by Robert Martin who contributes additional funds to
Blue Corporation sufficient to acquire all of Green Corporation's stock. For the current year, the affiliated
group reports the following results (excluding the consolidated NOL deduction):
Corporation Taxable Income

Blue $150,000
Gold ( 25,000)
Green (since acquisition) 100,000
Which of the following statements is correct?

A) Last year's NOL cannot be carried back.
B) The portion of last year's NOL that is not used as a carryback can be carried over the current year but is
only used against Blue's taxable income.
C) The portion of last year's NOL that is not used as a carryback can be carried over against the current
consolidated taxable income, but is subject to the Sec. 382 limitation.
D) The portion of last year's NOL that is not used as a carryback can be carried over, but is used only
against the Blue's and Gold's taxable income.
Answer: C
Objective: 6
60) Mariano owns all of Alpha Corporation, which owns 100% of Beta Corporation's single class of stock.
On January 1, Alpha and Beta Corporations report a consolidated NOL carryover from prior years. What
is the maximum percentage of Alpha Corporation's single class of stock that Mariano can sell to a single
shareholder without triggering the Sec. 382 loss limitation?
A) 0%
B) 50%
C) 75%
D) 80%
Answer: B
Page Ref.: C:8-33
Objective: 6
17
61) Last year, Trix Corporation acquired 100% of Track Corporation. The acquisition occurred on July 1,
which was five months after Track's creation. The corporations filed separate returns that year and have
filed consolidated returns since then. The group results for the years, excluding the NOL deduction, are
shown below.

Corporation
Trix ($12,000) $34,000
Track ( 10,000) ( 2,000)
Consolidated Taxable Income ($22,000) $32,000
Which of the following statements is incorrect?

A) Last year is an SRLY (separate return limitation year) with respect to Track Corporation.
B) Track's last year loss is offset against the consolidated current taxable income.
C) Track's last year loss can be used to offset the current year's consolidated taxable income.
D) None of Track's last year's loss can be used to offset the current year's consolidated taxable income.
Answer: C
Page Ref.: C:8-33
Objective: 6
62) Which of the following is not reported by an affiliated group on a consolidated basis?
A) capital gain
B) section 1231 gain
C) casualty & theft gain
D) All of the above are included.
Answer: D
Page Ref.: C:8-9
Objective: 3

A) Rules for carryforward and carryback of a consolidated net capital loss and a consolidated NOL are
the same with the exception of the carryforward period.
B) Capital loss carrybacks and carryforwards are all treated as short-term capital losses.
C) A member leaving an affiliated group cannot use capital loss carryovers that originated in one of its
previous separate return years.
Answer: B
Page Ref.: C:8-21
Objective: 6
18
64) Blair and Cannon Corporations are the two members of an affiliated group. No prior net Sec. 1231
losses have been reported by any group member. The two corporations report consolidated ordinary
income of $100,000 and gains and losses from property transactions as follows:
Sec. 1231
Corporation STCG/STCL LTCG/LTCL
Gains and Losses
Blair ($5,000) $6,000 $3,000
Cannon 6,000 (7,000) (3,000)
Included in the above totals is $6,000 of long-term capital losses recognized by Cannon on an
intercompany transaction. Excluded from the above is a $4,000 Sec. 1231 gain originally deferred by
Cannon that must be reported by the group in the current year.
Which one of the following statements is incorrect?

A) The consolidated group must report a net long-term capital gain of $9,000 and a net short-term capital
gain of $1,000.
B) Cannon Corporation's separate return reports a $6,000 net long-term capital gain.
C) The affiliated group reports a $4,000 net Sec. 1231 gain.
D) None of the above statements are incorrect.
Answer: B
Explanation: B) Statement A is correct because the group reports a $1,000 net short-term capital gain
[($5,000) + $6,000]. The group reports a $5,000 [($6,000 - $7,000) + $6,000 deferred loss] net long-term
capital gain before taking into account the Sec. 1231 gains and losses. The group reports a $4,000 [$3,000 -
$3,000 + $4,000 restored gain] net Sec. 1231 gain that is taxed as a long-term capital gain. The total is a
$9,000 net long-term capital gain. Statement B is incorrect because Cannon Corporation reports $6,000 of
short-term capital gains, $1,000 of long-term capital losses, and $1,000 of Sec. 1231 gains, or a net $6,000
short-term (and not long-term) capital gain. Statement C is correct because the affiliated group reports a
$4,000 net Sec. 1231 gain ($3,000 from Blair and $1,000 from Cannon after adding in the restored gain).
Objective: 6
19
65) Roland, Shedrick, and Tyrone Corporations formed an affiliated group a number of years ago, which
has since filed consolidated tax returns. No prior Sec 1231 losses have been reported by any group
member. The group had a consolidated capital loss carryover last year. For the current year, the group
reports the following results:
Ordinary Sec. 1231

Income Gains and Losses
Roland $25,000 $4,000 ($ 2,000) ($5,000)
Shedrick 30,000 (2,000) 14,000 ( 2,000)
Tyrone 20,000 (3,000) 8,000 ( 3,000)
Which of following statements is incorrect?

A) No Sec. 1231 recapture can occur this year.
B) The net capital gain is taxed at the regular corporate tax rates.
C) The Sec. 1231 loss is treated as an ordinary loss.
D) The net capital gain is $20,000.
Answer: D
Explanation: D) The net capital gain is $19,000 ($20,000 - $1,000).
Objective: 5
66) Blair and Cannon Corporations are members of an affiliated group. No prior net Sec. 1231 losses have
been reported by any group member. The two corporations report consolidated ordinary income of
$100,000 and gains and losses from property transactions as follows.
Sec. 1231
Gains and Losses
Blair ($5,000) $6,000 $3,000
Cannon 6,000 (7,000) (3,000)
Which of the following statements is correct?

A) The consolidated group reports a net short-term capital gain of $1,000.
B) Blair Corporation's separate return reports a $4,000 net long-term capital gain.
C) Cannon Corporation's separate return reports a $1,000 net long-term capital loss.
D) All three of the above are correct.
Answer: D
Objective: 5
20
67) Boxcar Corporation and Sidecar Corporation, an affiliated group, reports the following results for the
current year:
Ordinary
Income
Boxcar $10,000 $10,000 ($ 5,000)
Sidecar 30,000 (12,000) 16,000
The affiliated group's consolidated taxable income is

A) $40,000.
B) $49,000.
C) $51,000.
D) $52,000.
Answer: B
Explanation: B) ($40,000 - $2,000 + $11,000)
Objective: 5
68) Boxcar Corporation and Sidecar Corporation, an affiliated group, reports the following results for the
current year:
Ordinary
Income
Boxcar $10,000 $10,000 ($ 5,000)
Sidecar 30,000 (12,000) 16,000
What is the affiliated group's consolidated regular tax liability?

A) $7,700
B) $7,350
C) $6,650
D) $7,950
Answer: B
Explanation: B)
Ordinary income $40,000
Net STCL ( 2,000)
Net LTCG 11,000
Taxable income $49,000
Times: tax rate × 0.15
Tax liability $ 7,350
Objective: 5
21
A) When applying the large corporation rules for purposes of determining underpayments, each member
of an affiliated group is considered separately.
B) The entire consolidated tax liability cannot be collected from one group member.
C) Once consolidated tax returns have been filed for two consecutive years, the affiliated group must pay
estimated taxes on a consolidated basis.
Answer: C
Page Ref.: C:8-26
Objective: 9
70) The Alto-Baxter affiliated group filed a consolidated return for the first time last year. The group does
not come under the "large" corporation rules. For last year, the group reports a tax liability of $60,000.
Cooper Corporation has a $30,000 tax liability last year. This year, the Alto-Baxter affiliated group
purchased all of the Cooper stock. This year, the Alto-Baxter-Cooper group reports an $110,000
consolidated tax liability. To avoid penalties for the current year, the group must make timely estimated
tax payments of how much during the year?
A) $60,000
B) $90,000
C) $110,000
D) No estimated tax payments are required.
Answer: A
Page Ref.: C:8-26
Objective: 9
71) An affiliated group elects the use of the consolidated method for filing its tax return by
A) filing Form 1120.
B) filing a consent to the election from each member of the affiliated group in the initial year.
C) filing an affiliations schedule.
D) All of the above are necessary for the election.
Answer: D
Objective: 9
72) A consolidated return's tax liability is owed by

A) all group members in equal portions.
B) the group member responsible for that portion of the tax liability.
C) all group members who are severely liable.
D) the parent corporation.
Answer: C
Page Ref.: C:8-39
Objective: 9
22
73) Jeffrey Corporation owns 85% of Placer Corporation and 25% of Mercer Corporation. Placer
Corporation owns 60% of Mercer Corporation and 45% of Tyson Corporation. Jeffrey Corporation also
owns 85% of Apple Corporation and Apple Corporation owns 30% of Tyson Corporation. Which of these
corporations are members of an affiliated group if all percentages represent voting power and value held
by the respective corporations?
Answer: Jeffrey Corporation is the parent corporation with Placer, Mercer, and Apple Corporations as
members of the affiliated group. The 75% (30% + 45%) ownership of Tyson Corporation stock does not
meet the 80% ownership minimum.
Page Ref.: C:8-3
Objective: 1
74) Toby Corporation owns 85% of James Corporation's single class of stock and 35% of Mony
Corporation's single class of stock. James Corporation owns 45% of Mony's stock. The remainder of James
and Mony's stock is owned by 80 individual shareholders. Are the corporations part of an affiliated
group, and can they elect to file a consolidated tax return?
Answer: Since Toby owns more than 80% of the stock of James and therefore satisfies the direct
ownership requirement, and Toby and James together own 80% (45% + 35%) of Mony's stock, they are
affiliated corporations. The Toby, James, and Mony group can elect to file a consolidated tax return.
Objective: 1
75) Toby owns all of the single class of stock of James and Mony Corporations. James Corporation owns
all of Volt Corporation's stock. Mony owns all of Wegnin Corporation. Mony and Wegnin Corporations
are foreign corporations. Toby, James, and Volt are domestic corporations. Are the corporations part of an
affiliated group?
Answer: Toby, James, and Volt constitute the affiliated group. Toby is the common parent. Mony and
Wegnin are not included, as they are foreign corporations.
Page Ref.: C:8-2 and C:8-3; Example C:8-3
Objective: 1
76) Penish and Sagen Corporations have filed consolidated tax returns for several calendar years. At the
close of business on September 30, 2012, Penish Corporation sells its all of its Sagen stock to June. What
are the tax consequences to each corporation?
Answer: All of Penish's income is included in the consolidated tax return for 2012. Only nine months of
Sagen Corporation's income is included in the consolidated tax return for 2012. Sagen must also file a
separate tax return for the period October 1 through December 31, 2012.
Page Ref.: C:8-7
Objective: 3
23
77) P-S is an affiliated group that files a consolidated tax return. For the current year, P has separate
taxable income of $350,000 and S's separate taxable loss is $150,000. The group can take a tentative $50,000
consolidated general business credit. If the group's regular tax liability is $61,250 and their tentative
minimum tax liability is $34,500, what is their general business credit limitation? The only difference
between their taxable income and AMTI is the statutory exemption.
Answer:
Regular tax $61,250
Plus: AMT 0
Net income tax $61,250
Minus: the greater of
1. 25% of the group's net regular tax liability
exceeding $25,000 (0.25 × ($61,250 - $25,000) $ 9,062
2. The group's tentative minimum tax 34,500 (34,500)
General business credit limitation $26,750
The unused general business credit may be carried back one year and forward 20 years.
Objective: 5
78) Gee Corporation purchased land from an unrelated corporation several years ago for $105,000. The
land was used by Gee as a storage lot for company trucks. Gee sold the land to Wilkers, its 85%-owned
subsidiary corporation, last year (July 3) for $115,000. The land was also used in Wilkers' trade or
business. Wilkers Corporation sold the land for cash this year (August 22) for $130,000 to a corporation
that was not a member of the affiliated group. What gains and losses are recognized, deferred, or restored
by Gee and Wilkers Corporations?
Answer: Gee Corporation must report the $10,000 Sec. 1231 gain recognized on the sale of the land last
year to Wilkers in its separate taxable income. The gain is deferred by the affiliated group in determining
consolidated taxable income until the year the property is sold outside the group. The recomputed gain is
$25,000. Wilkers recognizes a $15,000 Sec. 1231 gain in the current year when it sells the land for cash to a
nonmember of the group. The group then restores the $10,000 balance of the recomputed gain as a Sec.
1231 gain.
Page Ref.: C:8-12
Objective: 4
24
79) Gee Corporation purchased land from an unrelated corporation several years ago for $105,000. The
land was used by Gee as a storage lot for company trucks. Gee sold the land to Wilkers, its 85%-owned
subsidiary corporation, last year (July 3) for $115,000. The land was also used in Wilkers' trade or
business. Wilkers Corporation sold the land this year (August 22) for $130,000 to a corporation that was
not a member of the affiliated group. The $130,000 purchase price is to be collected in five equal, annual
installments, commencing with the current year's sale date. What gains and losses are recognized,
deferred, or restored by Gee and Wilkers Corporations?
Answer: Gee Corporation must report the $10,000 Sec. 1231 gain recognized on the sale of the land last
year to Wilkers in its separate taxable income. The gain is deferred by the affiliated group in determining
consolidated taxable income until the year the property is sold outside the group. The recomputed gain is
$25,000. Wilkers recognizes a $3,000 gain Sec. 1231 gain ($15,000 × 0.20) in the current year when it sells
the land to a nonmember of the group and collects the first installment. The group then restores the
$10,000 balance of the recomputed gain as a Sec. 1231 gain ratably as the five installments are collected.
$2,000 ($10,000 × 1/5) of gain is restored when each of the five payments is received. A similar amount of
gain is recognized when each subsequent installment is collected.
Page Ref.: C:8-13
Objective: 4
80) Parent Corporation purchases a machine (a five-year property) for $20,000. It claims $4,000 of
depreciation under the MACRS rules in the first year it owns the property. At the close of business on the
last day of the first year, Parent sells the machine to a 100%-owned corporation (Subsidiary) for $18,000.
Subsidiary immediately commences depreciating the machine as a five-year property using the regular
MACRS rules. What depreciation can be claimed by Subsidiary Corporation in the first year it uses the
machine?
Answer: The basis of the machine to Parent on the sale date is $16,000 ($20,000 - $4,000). This basis and
the MACRS depreciation rules carry over to Subsidiary from Parent for this portion of the acquisition
cost. Parent recognizes a $2,000 gain ($18,000 - $16,000), which is deferred when the consolidated tax
return is filed. Subsidiary steps up its basis for the asset by the $2,000 amount, thereby providing a total
basis of $18,000. The basis increase is treated as a new asset by Subsidiary under the MACRS rules.
Subsidiary's depreciation calculation is:
Carryover basis: $20,000 × 0.32 = $6,400
Basis increase: $ 2,000 × 0.20 = 400
Total depreciation $6,800
Objective: 4
25
81) Parent Corporation purchases a machine (a five-year property) for $20,000. It claims $4,000 of
depreciation under the MACRS rules in the first year it owns the property. At the close of business on the
last day of the first year, Parent sells the machine to a 100%-owned corporation (Subsidiary) for $18,000.
Subsidiary immediately commences depreciating the machine as a five-year property using the regular
MACRS rules.
What gain is reported by Parent Corporation in the first year that Subsidiary Corporation depreciates the
machine?
Answer: The restored gain equals the depreciation taken ($400) by Subsidiary Corporation on the step-
up in basis. The gain is ordinary income under Sec. 1245. The basis of the machine to Parent on the sale
date is $16,000 ($20,000 - $4,000). This basis and the MACRS depreciation rules carry over to Subsidiary
from Parent for this portion of the acquisition cost. Parent recognizes a $2,000 gain ($18,000 - $16,000),
which is deferred when the consolidated tax return is filed. Subsidiary steps up its basis for the asset by
the $2,000 amount, thereby providing a total basis of $18,000. The basis increase is treated as a new asset
by Subsidiary under the MACRS rules. Basis increase: $2,000 × .20 = 400
Objective: 4
82) Jason and Jon Corporations are members of an affiliated group whose taxable incomes (before
dividends) are $90,000 and $100,000, respectively. Jason Corporation owns all of the Jon stock. Jon
Corporation received a dividend from a less-than-20%-owned corporation of $9,900 and $25,000 from a
100%-owned nonconsolidated insurance company. Jon Corporation distributed a $40,000 dividend to
Jason Corporation. Jason Corporation also received dividends from a 25%-owned corporation of $9,500.
The consolidated dividends-received deduction for federal income tax purposes is what?
Answer: [(0.70 × $9,900) + (0.80 × $9,500) + (1.00 × $25,000)] = $39,530. The $40,000 dividend is excluded
from Jason Corporation's gross income in preparing the consolidated return.
Page Ref.: C:8-22
Objective: 5
83) Parent and Subsidiary Corporations are members of an affiliated group. Their separate taxable
incomes (before taking into account any dividends) are $75,000 and $85,000, respectively. Subsidiary
Corporation receives a dividend from a less-than-20%-owned corporation of $7,500 and from an affiliated
100%-owned nonconsolidated insurance subsidiary of $40,000. Subsidiary distributes a dividend of
$35,000 to Parent Corporation who also receives dividends of $5,500 from a less-than-20%-owned
corporation. The consolidated dividends-received deduction is what?
Answer:
70% deduction: Consolidated deduction:
0.70 × $5,500 = $3,850 100% dividends-received deduction $40,000
0.70 × $7,500 = 5,250 70% dividends-received deduction 9,100
Total $9,100 Total $49,100
Objective: 5
26
84) A consolidated NOL carryover is $52,000 at the beginning the year. Twenty-five percent of the loss is
allocable to Duke Corporation. Duke Corporation leaves the group in the middle of the affiliated group's
tax year. Before Duke's departure, it had earnings of $15,000 for the year, and the remainder of the
affiliated group earned a total of $25,000, or $40,000 of taxable income for the group, excluding any NOL
carryover. Following its departure from the affiliated group, Duke earned $8,000 in its first separate
return. How much of the $52,000 NOL can Duke use on its first separate return?
Answer:
$ 15,000 Duke contribution to current year CTI
25,000 Plus: other members' contribution to current-year CTI
$ 40,000 Current-year CTI
( 52,000) Minus: NOL available
($ 12,000) NOL carryover available to be used on separate return or consolidated tax return
× 0.25 Allocation to Duke
$ 3,000 Amount allocated to Duke
The entire $3,000 can be used since it is less than Duke's pre-NOL taxable income.
Objective: 6
85) On January 1, Alpha Corporation purchases 100% of the stock of Omega Corporation for $2 million.
During the year, Omega Corporation earns $350,000 of taxable income, $30,000 of tax-exempt income,
and distributes $150,000 in dividends. Each company paid its own tax liability. Assume a 34% tax rate.
What basis adjustment must Alpha Corporation make at year-end?
Answer: Alpha Corporation's initial basis for the Omega Corporation stock is its $2,000,000 purchase
price. The $350,000 of taxable income and $30,000 of tax-exempt interest income earned in the current
year increase the stock basis. The $119,000 ($350,000 × 0.34) federal income tax liability decreases the stock
basis, as does the $150,000 distribution to the parent corporation (Alpha). The year-end basis is $2,102,000
($2,000,000 + $350,000 + $30,000 - $119,000 - $159,000). The year-end basis for the Omega Corporation
stock is $111,000 ($350,000 + $30,000 - $119,000 - $150,000) higher than its $2,000,000 acquisition cost.
Objective: 7
86) Explain the requirements a group of corporations must meet in order to elect to file a consolidated
return.
Answer: The parent corporation must own at least 80% of the total voting power and at least 80% of the
total value of all outstanding stock in at least one includible corporation. Each additional corporation that
is included must also meet the two 80% stock ownership rules either directly or indirectly. Eligible
affiliated groups must make a consolidated return election by filing a timely consolidated tax return.
Objective: 1
27
87) What types of corporations are not includible corporations for purposes of determining whether or
not an affiliated group exists?
Answer: Special tax status corporations are not includible corporations.
• Exempt corporations under Sec. 501
• Insurance companies subject to tax under Sec. 801
• Foreign corporations
• Corporations claiming the Puerto Rico and U.S. possessions tax credit
• Regulated investment companies
• Real estate investment trusts
• Domestic international sales corporations
• S corporations
Page Ref.: C:8-3
Objective: 1
88) What are the differences between a controlled group and an affiliated group?
Answer: Three forms of controlled groups are permitted — brother-sister groups, parent-subsidiary
groups, and combined groups. Only parent-subsidiary groups and the parent-subsidiary portion of a
combined group can elect to file a consolidated tax return. Four primary differences between a controlled
group and an affiliated group exist. First, the two 80% stock ownership tests must be met to have an
affiliated group. Only one of the tests needs to be met to have a controlled group. Second, the controlled
group definition uses certain stock attribution rules and included and excluded corporation rules that are
not used in testing for an affiliated group. Third, certain special status corporations are excluded from the
affiliated group definition that may be included in a controlled group. Fourth, the controlled group
definition is tested only at December 31. The affiliated group definition must be tested on each day of the
year. See Chapter C3 for further discussion of controlled group topics.
Page Ref.: C:8-4
Objective: 1
89) What are the five steps in calculating consolidated taxable income?
Answer: Generally, the five steps are:
1) Compute each group member's taxable income (or loss) based on the member's own accounting
methods as if the corporation were filing its own separate tax return.
2) Make adjustments to each group member's taxable income for certain intercompany transactions,
inventory adjustments, dividends received, excess loss (negative investment basis) accounts, and built-in
deductions.
3) Remove certain gains, losses, and deductions from each member's taxable income since they must be
computed on a consolidated basis (e.g., NOLs, capital gains and losses, Sec. 1231 gains and losses,
charitable contribution deductions, dividends-received deduction, percentage depletion under Sec.
613A).
4) Steps 1 through 3 result in the member's separate taxable income. Combine these amounts to equal
the group's combined taxable income.
5) Adjust the group's combined taxable income for items reported on a consolidated basis to equal the
consolidated taxable income.
Page Ref.: C:8-9; Table C:8-1
Objective: 3
28
90) Why are other intercompany transactions not given any special treatment?
Answer: Since both sides of the transaction are reported in the same consolidated return, they simply net
each other out. If, due to accounting methods, the items would be reported in different tax periods, both
the income and deduction must be reported in the later of the two tax years.
Objective: 4
91) Define intercompany transactions and explain the two types of transactions.
Answer: An intercompany transaction takes place during a consolidated return year between
corporations that are members of the same affiliated group immediately after the transaction. The two
types of intercompany transactions are property and other intercompany transactions. Intercompany
property transaction gains or losses are deferred until a corresponding event occurs. Other intercompany
transactions income or expense is reported in the year in which the corresponding event occurs.
Objective: 4
92) Alpha, Beta, Gamma, and Delta Corporations form a controlled group. Delta is a nonincludible
regulated investment company. Only Alpha, Beta, and Gamma are able to file their income tax returns on
a consolidated basis. What options are available for allocating the 15%, 25%, and 34% tax rates to the
members of the controlled group?
Answer: The benefit that the controlled group receives from the 15%, 25%, and 34% graduated tax rates
are limited. The group only receives one rate reduction for each reduced tax rate bracket. Where no
special apportionment plan is adopted, each bracket is divided equally between the members of the
controlled group. Under our facts, Alpha, Beta, Gamma, and Delta each would be allocated $12,500 of the
15% bracket, $6,250 of the 25% bracket, and $2,481,250 of the 34% bracket. This method will not result in
the lowest overall tax liability if, for example, one or more of the four- member corporations of the
controlled group incurs a loss or has taxable income below $18,750 ($12,500 + $6,250). In this situation, the
tax savings generated by the lower two rate brackets will not be fully used. A solution to this problem is
the adoption of a special plan of apportionment. With this plan, the group has the latitude to allocate the
brackets so as to achieve the maximum tax savings by allocating the reduced tax rates to each member
corporation based on its level of taxable income. This plan must be filed with each corporation's tax
return and is elected each year. Therefore, it can be adjusted to fit each year's facts. Since Delta is a
nonincludible corporation, it will receive an allocable share of the reduced tax rate benefits unless a
special apportionment plan is elected, even though it is not part of the consolidated return.
Page Ref.: C:8-24
Objective: 5
93) What is the carryback and carryforward rule for consolidated NOLs?
Answer: A consolidated NOL may be carried back to the two preceding consolidated return years or
carried over to the twenty succeeding consolidated return years.
Page Ref.: C:8-28
Objective: 6
94) What is the consequence of having losses subject to the SRLY limitations?
Answer: The effect of having a loss tainted as an SRLY loss is that it can be used only to offset taxable
income of the subsidiary member (or possibly loss subgroup) that created the NOL.
Page Ref.: C:8-31
Objective: 6
29
95) How do intercompany transactions affect the calculation of capital gains/losses?
Answer: Deferred intercompany gains/losses are included in the netting of capital gains/losses only
when a corresponding item triggers the recognition of the intercompany item.
Page Ref.: C:8-21
Objective: 5
96) What issues determine whether an affiliated group exists?

Answer: In determining whether an affiliated group exists, three questions must be answered.
• Does a corporation (common parent) directly own 80% or more of at least one includible corporation?
• What are the includible corporations?
• What chains of includible corporations are connected by at least 80% ownership?
Page Ref.: C:8-3
Objective: 1
30
97) All of the stock of Hartz and Ryder Corporations is owned by Morgen. Hartz Corporation has been
reporting $150,000 of taxable income for each of the past five years. Ryder Corporation has been reporting
$30,000 in NOLs for the same period, which totals $150,000. Approximately one-third of Hartz's profits
come from sales to Ryder. Intercompany sales between Hartz and Ryder have increased during each of
the last five years. What tax issues should Morgen consider with respect to his investments in Hartz and
Ryder Corporations?
Answer:
• What advantages would accrue if the Hartz-Ryder affiliated group elected to file a consolidated tax
return?
• Can the profits earned by Hartz Corporation on an intercompany inventory sale to Ryder
Corporation be deferred for tax purposes?
• Can the current-year losses of Ryder Corporation offset the current-year profits of Hartz
Corporation? Are there any restrictions or limitations on deducting the losses?
• Can the preaffiliation losses of Ryder Corporation offset the consolidated taxable income? Are there
any restrictions or limitations on deducting the losses?
• What disadvantages would accrue if the Hartz-Ryder affiliated group elected to file a consolidated
tax return?
• Is additional recordkeeping involved in filing a consolidated return instead of two separate tax
returns?
• What types of corporate groups can file a consolidated tax return?
• What are the stock ownership and includible corporation requirements for an affiliated group?
• Do Hartz and Ryder Corporations as brother-sister corporations satisfy these requirements?
• If an affiliated group does not exist, what changes to the corporate structure must be made to create
an affiliated group?
The current brother-sister relationship for Hartz and Ryder Corporations does not permit the filing of a
consolidated tax return. If a parent-subsidiary relationship were established (e.g., by Morgen's capital
contribution of the Ryder stock to Hartz Corporation), a consolidated tax return could be filed.
Postchange NOLs for Ryder Corporation could offset the profits of Hartz Corporation in the consolidated
tax return. The prechange NOLs are SRLY losses and can be used by the affiliated group only to the
extent that Ryder subsequently earned profits. An adjustment to the transfer price charged for the
product produced by Ryder might permit additional profits to be earned by Ryder and accelerate the use
of the SRLY losses. Profits earned on the intercompany inventory sales are deferred under the
consolidated return rules. Too large of a transfer price change may be indicative of tax avoidance and
cause the IRS to apply Sec. 482 to the intragroup transfers. These deferrals have increased annually over
the last five years. Depending on the inventory method employed (e.g., LIFO or FIFO), the tax deferral
could either be short-term or long-term. Two drawbacks to the filing of a consolidated return are the
additional recordkeeping involved in maintaining the records and preparing the tax returns, and the
smaller deduction and credit limits faced by the group over what Hartz Corporation would have on a
separate return basis.
Objective: 8
31
98) Marietta and Alpharetta Corporation, two accrual method of accounting corporations that use the
calendar year as their tax year, have filed consolidated tax returns for a number of years. Alpharetta
Corporation, a 100% owned subsidiary of Marietta, is transferring a patent, equipment, and working
capital to newly created Georgia Corporation in exchange for 100% of its stock. In 2011, the corporation
will begin to produce parts for the computer industry. Georgia Corporation expects to incur
organizational expenditures of $10,000 and start-up expenditures of $60,000. What tax issues should
Georgia Corporation consider with respect to the selection of its overall accounting method, inventory
method, and tax year, and the proper reporting of its organizational and start-up expenditures?
Answer:
• What tax year can Georgia Corporation elect?
• What overall method of accounting can Georgia Corporation elect?
• What inventory method can Georgia Corporation elect?
• How does Georgia Corporation treat its organizational expenditures? Its start-up expenditures?
Georgia Corporation must use the same tax year as the other two corporations in its affiliated group. In
general, Georgia Corporation can elect to use the cash, accrual, or hybrid methods of accounting.
However, since it is producing parts for the computer industry, inventories will be a material income
producing factor, and it must use the accrual method of accounting for its sales-related activities. It is
possible for Georgia Corporation to use the hybrid accounting method, and if such an election were
made, Georgia would not be required to use the accrual method of accounting for its other income and
expense items. It need not use the same accounting methods as the other two corporations in the affiliated
group. Georgia Corporation can elect any of the inventory methods acceptable under Sec. 471. It does not
need to use the same inventory method as the other two corporations in its affiliated group. Georgia
Corporation can elect to amortize its organizational expenditures and its start-up costs whether or not the
other two corporations have made similar elections. There is no restriction under Code Secs. 195 and 248,
or the consolidated tax return regulations, that similar treatment of such expenditures be followed by all
three corporations.
Objective: 3
32
99) Blitzer Corporation is the parent corporation of a 10-member group that has filed consolidated tax
returns for a number of years. Last year, the group sold all the stock of Wolf Corporation to Jerry Jensen.
This year, Wolf Corporation reported a $300,000 NOL. Wolf's taxable income while a group member
averaged $200,000 annually for the past five years but is expected to be only $50,000 next year due to
start-up costs that will be incurred with the introduction of a new product line. Profits are expected to
increase in each succeeding year. What issues should Blitzer have considered when trying to value Wolf's
NOL prior to its sale? What tax issues should Wolf now consider when deciding how to use its NOL?
Answer:
• What alternatives exist for using the NOL?
• Can the separate-return NOL of Wolf be carried back to a consolidated tax year of the Blitzer
affiliated group?
• If so, what special limitations (if any) is the NOL subject to?
• What is the projected tax refund if the NOL is carried back to a prior consolidated return year?
• Who files for the tax refund? Who receives the refund from the IRS?
• Was any provision made for Wolf receiving the NOL refund payment from the Blitzer affiliated
group in the stock purchase agreement should a separate NOL be carried back?
• What is the projected taxable income of Wolf Corporation in the future?
• What is the projected tax refund if the NOL is carried forward to a separate return year(s)?
• What special limitations (if any) is the NOL subject to (e.g., Sec. 382 restrictions following a change in
ownership)?
• How is the election to forgo the NOL carryback made?
• What effect does the low taxable income in the future years and the Sec. 382 limitation have on the
valuation of the NOL? The company?
A larger tax refund should be available to Wolf Corporation by carrying the NOL back to the prior tax
years of Blitzer Corporation. The marginal tax rate for the earlier tax years appears to be 39% while Wolf
has a 15% rate for the near future. The separate-return NOL is an SRLY loss when carried back, and its
use is subject to the SRLY limitations. The entire loss carryback should be absorbed within the two-year
carryback period since Wolf reported separate-return profits of $200,000 annually when part of the
affiliated group, Wolf files for the refund based on the carryback. A carryover of the NOL is likely subject
to the Sec. 382 loss limitations. We do not know enough about Wolf's new owners to be able to reach a
definite conclusion about the Sec. 382 issue. The tax refund from an NOL carryback will be paid to
Blitzer. As such, Blitzer may be reluctant to pay the refund to Wolf unless such an event was agreed upon
at the time of the sale. From Wolf's perspective, the sales agreement should include a provision requiring
Blitzer to pay the refund to Wolf Corporation.
Objective: 6
33
Another random document with
no related content on Scribd:
argue from them that God’s ways are wider and more merciful than
the heart of man can fathom.”
“Bride is unhappy about several persons who seem to be wandering
so far away from the fold,” said Mrs. St. Aubyn, in her gentle tones.
“She is suffering, as we all suffer at some time or another, when
those we love seem rather against than with us. Can you say
something to comfort her? I think she has come here for a little bit of
comfort. Have you not, my child?”
Bride’s soft eyes swam in tears. She was rather unhinged by her
own intensity of thought. The motherly words almost broke her down.
Mrs. St. Aubyn took her hand and caressed it gently. The clergyman,
after a moment of silence, spoke, in his thoughtful tender fashion—
“Yes, we have so much cause for hope, even for those who have
gone far, far astray. We must not think of them as sundered from the
love of the Father, for we know that He does not so regard them,
even though His heart may be full of pain at the thought of their
transgressions and neglect. We have such beautiful lessons set
before us by our Lord, who knew the heart of the Father as none of
us can know it. Let us think, just for one minute, of that wonderful
story of the prodigal son.”
Bride raised her face quickly.
“He repented,” she said softly.
“Yes,” said Mr. St. Aubyn, “he had been full of self-will and folly. He
had gone very far from the father’s house, and the place which was
his there by the father’s wish. He was in a far country. He had
squandered the gifts of a loving father—the talents, the faculties, the
opportunities—upon unworthy and sinful objects. He had followed
the dictates of his own heart, and had not heeded his father’s loving
counsel and admonitions; and at the last he was reduced to husks,
those unsubstantial and empty husks which are in the end all that is
left to us of a life of worldly pleasure, take what form it will at the
outset. Only the husks remained, and the hunger of the soul set in,
which is the worst hunger of all to bear. When that stage has been
reached, the backward glance to the father’s house becomes
inevitable. The young man in the far country felt it; and I think there
was much more than the mere craving for physical comforts in the
resolve which was embodied in the words, ‘I will arise and go to my
father.’ There is much more than that in those words of penitence,
followed up by the resolve to ask, ‘Make me as one of thy hired
servants.’ That was what the son set out to say—‘make me as one of
thy hired servants;’ but when he reached his father he could not say
it. Why not?”
Bride was silent. The tears were still in her eyes. Mr. St. Aubyn
looked at her, looked at his wife, and then went on softly—
“He could not say it because he was ashamed to say it—because
the love of his father, the love which was watching for him after all
these years of absence, which went out to meet him whilst he was
yet a great way off, which wrapped him round in its embrace in that
mysterious fulness of fatherhood, shamed him into silence. He could
confess his sins and his unworthiness; perhaps at no moment had
he ever felt so utterly humiliated, yet he could not say ‘make me as
one of thy hired servants’—the father’s love had taught him his place
as a son; the father’s love had broken down the last barrier of
reserve. Unworthy, humbled to the dust, broken down by his
emotion, he yet knew that it was as a son he was received back; and
the deep unchanging love of the father shamed him, I say, from
trying to seek the lower place. When God gives us the right to call
ourselves sons, is it for us to say, ‘Nay, Lord, but let me be as a hired
servant?’ Is that the humility that the Lord asks of us? Is that the
truest faith?”
Still Bride was silent, and as if in answer to her unspoken thought,
Mr. St. Aubyn continued—
“Thank God it is given to some of us to remain ever in the Father’s
house. We have not been tempted to stray from it. We live in His
love, and seek every day to do Him service. But there is always the
peril to us of looking abroad at our brothers who have wandered
away, and of asking ourselves, sometimes in tender anxiety,
sometimes with a sense of compassionate disfavour, sometimes
perhaps in something too nearly approaching scorn, whether for
them there can ever be a return to the Father’s house, whether they
will ever be worthy to be received there once more, even if they do
return; and there are not lacking those amongst us, I fear, who would
sometimes, consciously or unconsciously, deny them their place in
the home, judging them to have lost it for ever through disobedience
and rebellion.”
Bride clasped her hands together, her soft eyes shining.
“Oh, go on,” she said softly; “tell me the rest.”
“It has been told already, my child, told in the reception of the erring
son, not as a stranger or a servant, but as a son. The love of the
Father transcends our love for our brethren, as much as did the
father’s love transcend that of the jealous elder son. It is not for us to
despair for the wanderers, for the Father does not despair of them.
He watches for them, and when their faint and lagging footsteps are
homeward turned, irresolutely perhaps, fearfully perhaps,
despondently perhaps, while they are a great way off he goes
Himself to meet them. He sends no servant; He sends no brother
even; He goes Himself. And then, when the lost son feels the
Father’s arms about his neck, hears the Father’s voice speaking in
his ear, the faint and fearful love of his heart is turned to a deep
stream of true filial devotion, and he knows himself in all his
abasement and humility for a son, and the first word he speaks,
amidst his tears, is the word ‘Father.’ And after that word is spoken
there can be no talk of being a hired servant. Father!—our Father—
that is the essence of Christ’s redeeming work on earth.”
“Thank you,” said Bride, drawing a long breath; “I think you have
given me comfort. I was too much like the elder brother, too much
inclined to despair of those who had strayed away. I will think of
them differently now. Surely they will one day turn back to the home
again.”
“I trust so; we can at least pray that it may be so. Prayer is the
strongest power there is for leading men back to God; and I often
think and note that, when He would draw to Himself an erring son
who will not pray for himself, He puts it into the heart of a brother or
a sister to pray for him, and so the erring one is drawn back towards
the Father’s house.”
Bride’s face quivered as she held out her hand in farewell, but she
went home greatly comforted.
CHAPTER XIII
TWO ENCOUNTERS
BRIDE was riding slowly down the hill from St. Erme’s on her little
Exmoor pony, with a grave and sorrowful face. Around her the green
billowy downs stretched away in all their bright spring greenness,
overhead the larks were carolling as though their hearts were filled
with rapture, whilst far below the sea tossed and sparkled in the
brilliant sunshine in a fashion that was exhilarating and gladsome.
It was a day late on in March—one of those days not unfrequent at
that season, especially in the south and west—a day that seems
filled with a promise of coming summer—a day in which all nature
rejoices, which stirs the pulses and sets the blood coursing joyously,
and fills the air with subtle promises of life and hope.
Bride’s face had been tranquil and happy as she rode up the heights
towards Farmer Teazel’s farm, but it was sorrowful and troubled now
as she returned, for she had failed in the mission on which she had
been bound, and was experiencing one of those revulsions of feeling
which often follow upon a period of solitary meditation and resolve,
when the dreamer is brought face to face with the stern realities of
human life and human nature.
Bride’s mission to the farm had been to plead with the farmer to offer
a place in his service to Saul Tresithny, now just out of prison. His
sentence had been up a few weeks earlier, but he had been ill of
fever in the prison hospital when the period of release came, and
had only that week been set at liberty.
All through the term of his imprisonment Bride’s thoughts and her
prayers had been much exercised with him. The compassion she felt
towards him partook of the nature of a great yearning tenderness,
curious in a girl of her age and station, and she could not help
believing that her feelings must be in some sort reflected in the
minds of others. Her father she knew felt compassion for Saul,
though he seldom spoke his name. Abner, as was natural, yearned
over his grandson with a great love and tenderness, and both Mr.
Tremodart and Mr. St. Aubyn were interested in him, and were willing
to give him occupation in their service on his release, if he would
accept it. But Saul’s known aversion to service in any of its branches
was too well known in the place for any one to have much hope of
his falling in with either of these offers. Abner shook his head
whenever he was questioned on the subject, and said he feared
Saul had not changed or softened with his incarceration. But the
thought came to Bride that if his old master the farmer, with whom he
had always got on so well, would offer him his old place at the farm,
that offer would be accepted, and she had gone up to talk poor
Saul’s case over with the kind-hearted yeoman, and get him to see
the matter in the light that she herself viewed it.
But only disappointment and sorrowful surprise awaited her here.
Farmer Teazel was a thoroughly kind-hearted man, and very fond
indeed of the little Lady Bride, whom he had known ever since her
infancy. He loved to see her riding up to his farm on the pony of his
own breeding and choosing. He was all smiles and kindness till her
subject was broached, and then she found that there was a limit to
his benevolence, and to the influence she had over him—a barrier
like a ledge of hard rock against which her arguments rebounded
helplessly.
Saul Tresithny had sinned in a fashion the farmer could not forgive,
and he had no pity upon misfortune deliberately run into by a man
who has had every opportunity of knowing better. The fact that Saul
had averted the attack upon his own homestead did not weigh with
him here. He argued that Saul had had his revenge on his (the
farmer’s) machines before this. The sturdy yeoman had his own
grievance against Saul and his teaching, and was not disposed to be
grateful for the other deliverance. No, Saul was a reprobate and a
jail-bird, and he would have none of him. He had had enough of the
mischief his tongue did before. It wasn’t in reason he should put up
with it again. No, no; he was sorry to refuse Lady Bride anything; but
ladies did not understand these things—did not understand the
nature of great, ill-conditioned demi-gods (as he called it in his haste)
such as Saul had become. It was no use talking to him of
forgiveness and mercy. It would be time enough for that when the
man had repented. He hadn’t ever learned that there was any call to
forgive before the sinner was sorry. From all he heard, Saul wasn’t a
bit humbled or penitent. It would only be the old trouble over again if
he came back; the farmer would take care he had nothing more to
do with such a fellow.
When Bride had exhausted her eloquence upon the farmer, and he
had gone out to his work again, she tried what she could do with the
daughter; but Genefer was even more impracticable than her father.
Half ashamed of ever having given encouragement to Saul, who had
behaved so cavalierly to her afterwards, she was bitterly set against
him, and did not pick her words when launching forth about him.
Moreover, Genefer was now openly betrothed in marriage to young
Farmer Hewett, and was mortally afraid lest he should ever hear that
she had permitted Saul to make love to her. She would not for
anything in the world have had him again at the farm, and Bride was
forced to ride away downcast and sorrowful, wondering in her heart
how it was that people of the same class were so hard upon one
another, and musing by degrees on the result to the community of a
gradual change which should practically throw the governing power
into the hands of the masses. Would that power be exercised on the
side of mercy and love, or would it become only a new form of
tyranny and hardness, far more difficult to modify and soften than
any monarchical harshness of rule? It was a question she could not
answer, but it helped to keep her face grave and her brow sad as
she rode slowly down the hill, rode right down by the rough lane to
the cottages upon the shore, where she had an errand of mercy to
perform; and leaving her pony to nibble at the salt herbage at the
base of the rocks, as he loved to do, she walked forward alone
towards the margin of the sea, and came suddenly and quite
unexpectedly face to face with Saul Tresithny, who was sitting in the
hot sunshine on a rock, and gazing out over the sea, with those
strange dark eyes of his that gleamed with sombre fire.
She knew that he was free, but thought him still at Pentreath, he
having refused to come to his grandfather’s cottage on his release.
The recognition was mutual, and the man instinctively, though
sullenly, rose to his feet. Bride glanced up at the tall towering figure,
which looked taller than before in the gauntness of recent illness.
There was something rather terrible in the gloom of the cadaverous
face. Saul had been stricken down with that terrible fever which was
so common in prisons during the previous century, and went by the
significant name of jail-fever, and which still lingered about those
prisons which were overcrowded or unsanitary, and generally
claimed for its victims those who were unused to confinement and a
close atmosphere, and had led an open-air life hitherto.
The terrible sufferings Saul had endured during six months of
imprisonment were too clearly written on his face to evade
observation. What such incarceration meant to one of his nature and
training can only be realised by those who have lived the life he had
hitherto led, and have been out in the open air from dawn till dark
every day of their lives, summer and winter, from boyhood. Bride
shrank back as she saw his face, with a sense akin almost to terror;
but then her sense of Divine compassion and tenderness for the wild
impenitent prisoner came back with a bound, and she put out her
little gloved hand and laid it on his arm.
“Saul, I have been so sorry for you, so very sorry,” she said, softly
and gently. “But it is over now, and you have life still before you. You
will learn to——”
“To forget? never!” interrupted he, with a strange flash in his eyes. “I
will never forget, ay! and never forgive, to the end of my days.
Stacked like pigs in a stye, crowded together in hunger and dirt, and
wretchedness unspeakable, the best man amongst them hanged by
the neck till he died, and all for preaching the gospel of truth to a
down-trodden people, that is what England has to look for from her
rulers! That is what we have to look forward to who strive to raise our
brothers from abject misery and degradation. Forget! No, I will never
forget. I will avenge those months of misery, and the death of my
best and truest friend; ay! I will avenge it on the proud heads of the
tyrants of this land. Don’t come near me, don’t speak to me, Lady
Bride. I would not hurt you willingly; but there is that within me that
may prompt me to do you a mischief if you stand there much longer.
Go, I say, go! You are a woman; I believe you are a good and a
merciful woman; but you come of a race that is doomed. Go, let me
never see you here again! Look to yourself, and let your father look
to himself, for they have made a Cain and an Ishmaelite of me; and I
will be in very truth what they have made me. I will give them cause
to tremble!”
But Bride looked at him with quiet fearlessness, sorrowful, yet not
afraid. That the fever and weakness, combined with long months of
brooding and suffering, had partially clouded his brain, she could
well understand. His threats did not alarm her. She knew he would
never lay a finger upon her.
“I am very grieved for you, Saul,” she said again. “It has been very
hard to bear, and the more so because all the while you believed you
were doing right. That is what is so hard to understand in this world
—how to do right without doing wrong too; and there is only one
Power that can help us to know that. I hope some day you will learn
to know that Power, and see with unclouded eyes. Meantime, if you
will let me, I should like to help you and to be your friend. I think you
know that you may trust me, even though you may not be able to
help hating me.”
He looked at her with a strange expression in his hollow eyes that
sometimes burned so brightly, and sometimes were clouded over
with a mist of bewilderment and semi-delirious imaginings. He
looked at her as though about to speak, but then suddenly closing
his lips, he turned hastily away and walked rapidly, though a little
unsteadily, in the opposite direction; whilst a woman from a
neighbouring cottage came hurrying out, and Bride saw that Mother
Clat was approaching.
“’Tidden wise o’ yu tu talk wi’ yon lad out heer alone, Laady Bride. He
be maazed wi’ t’ prison vever, he be,” she said anxiously, with a
backward glance over her shoulder at the retiring figure of Saul.
“Duee go tu home now, and letten ’lone tu coom tu hisself. Yu’ll on’y
be aggin’ he on to du wusser ef zo be as yu try to talk un zoft.”
“I am very sorry for him. He looks very ill,” said Bride
compassionately. “Do you know where he is living now?”
“He du be bidin’ wi’ me these past tu daays,” answered the woman;
“I wunt zay how long he’ll bide. He’s gotten zome money, an’ he’s a
rare hand wi’ th’ bwoats. I reckon he can maake a shift to live down
along wi’ we, ef zo be as he’s got a mind tu.”
“Take care of him, then,” said Bride pleadingly. “I think he wants care
and good food whilst he looks so thin and gaunt. Give him all you
think he needs, and I will take care you are no loser. Don’t say a
word to him, but just let me know. See, I will leave this crown with
you now. Get him everything he ought to have. I never saw anybody
so dreadfully changed before.”
The woman took the coin and nodded. She was perfectly to be
trusted, despite the peculiarity of her position in St. Bride as the
known ally of smugglers, and the cleverest hider and concealer of
contraband goods in the place. Bride perfectly recognised the
distinction between general dishonesty and this particular sin, so
common in those days amongst men otherwise upright and
trustworthy. She left the bay a little comforted by learning that Saul
had at least a roof over his head, and was amongst men who liked
and trusted him. Mother Clat was, with all her witch-like aspect and
rough speech, a kind-hearted woman, and would do her best for her
lodger. Saul was better here by the salt sea waves than in some
poor lodging in Pentreath. Evidently the death of the cobbler and the
scattering of the little band of malcontents had for the time shattered
his dream of becoming a semi-professional agitator. The fascination
of the blue sea, the boundless sky, and the tossing salt waves had
drawn him back to St. Bride’s. If only some gentler influence could
be brought to bear upon him, he might yet become a changed
character with patience and time.
“If Eustace could see his pupil now, what would he think?”
questioned the girl to herself, as she rode up the rough beach path;
and she wondered to herself whether his influence, could it be
brought to bear, would be for good or for ill—though this seemed but
idle speculation, as Eustace was far away in London, and she did
not think he would visit Penarvon for long enough to come. Musing
thus, she turned in at the lodge gate and rode quietly up the zigzag
track through the pine wood, till, arriving at the point where the road
divided, she took the right-hand fork and rode direct to the stable-
yard, and three minutes later reined in her pony in the big enclosure,
a groom coming forward to assist her to dismount.
Three strange horses stood tied up in the yard, looking as though
they had been ridden somewhat hard that day. Stablemen were
grooming them down with assiduity, the head-coachman looking on
and making remarks from time to time to his subordinates. As he
saw his young mistress he came respectfully forward.
“Has some visitor arrived?” she asked, with a glance at the strange
horses; but there was no need for the man to answer. At that
moment a tall figure entered the yard through the door of the
covered way leading from stable-yard to house—entered hurriedly,
as though to give some forgotten order, and Bride found herself face
to face with her cousin Eustace.
They both started slightly, but Bride recovered herself immediately,
and quietly offered her hand.
“This is an unlooked-for pleasure,” she said gently; and his face
flushed from brow to chin beneath the bronze of the sunny journey in
March shine and blow.
“Thank you,” he answered, pressing her hand gratefully; and then,
turning for a moment to the coachman, he gave the instruction in
reference to his horse which he had come to deliver. That done, he
turned once more to Bride and said—
“Your father is not within—he has ridden out too. I thought I should
have to wait for any welcome. I trust that I have not taken an
unwarrantable liberty in coming thus unannounced, but I have news
that I thought would interest the Duke, and it is necessary that I
should have personal speech with him.”
“I am sure my father will bid you welcome to Penarvon,” answered
Bride, with gentle dignity. “I trust the news that you bring is good and
not bad.”
“I trust so myself. It is news that cannot fail to stir all hearts more or
less at such a time. Parliament is dissolved. There is to be a new
appeal to the electors of the country!”
Bride paused to look at her cousin’s face, which was full of an
enthusiasm and glad hopefulness that was almost infectious. Instead
of taking the covered way back to the castle, the cousins were slowly
following the longer road by which horses and carriages travelled.
Bride caught her long skirt up with one hand, the other held her whip.
Her face was flushed with the surprise of this second unlooked-for
encounter. Eustace thought he had never seen her look more lovely
than at this moment, in the close-fitting habit and picturesque hat
with its waving plume.
“A dissolution!” she exclaimed; “I thought the king was altogether
averse to that. I thought your bill had just achieved its second
triumph.”
“It has, and it has not. The papers have kept you conversant with the
bald facts of the case. But what it comes to is this, that without a
more powerful majority than we have now, such a measure as ours
cannot be successfully passed through the House. It would be so
mauled and mutilated in committee that it would utterly fall to pieces.
We must know now what the country feels on this great question. We
must feel the pulse of the nation. It is the only thing to do. The king
was against the measure; but the voice of wisdom prevailed. As
soon as his consent was gained, I took horse and started off. I
wished to be the first to bring the news to Penarvon. Tell me, Bride,
what have these six months done for my uncle in modifying or
changing his views on this question? He now knows the just and
moderate terms of the bill. Does he feel against it all the same
prejudice he did at the outset, when we none of us knew exactly on
what lines it had been framed?”
“I do not think he feels any very great hostility to the present bill,”
answered Bride quietly. “He has fully recognised that there are
abuses with regard to the representation of the country that may well
be mended, and on the whole I think he admits the present measure
to be moderate and wise. But he knows as well as you know that this
is only the beginning, and whilst you approve heart and soul the
movement of which it is the pioneer, he distrusts and dreads it. That
is why the success of even a wise measure fills him with no
enthusiasm. He still believes that the abuses which will grow up
under your new régime, when it is established, will far transcend
those which flourish under the old, and that sin and want and misery
will increase rather than diminish. That is as much as I can tell you of
his opinions, for he does not talk of this thing often. The subject is
rather a painful one to him. It brings with it a sense of helplessness,
a sense of drifting away from the old moorings into a troubled sea for
which he has no chart or compass. I think he knows that the thing
must be; but he does not look forward with joy to the future it will
bring in its wake.”
“At his age that is perhaps natural,” answered Eustace. “He is a
more liberal-minded man than many of his generation and position. I
am thankful he is not bitter in opposition, for I shall want something
from him that he might be very loth to give did he feel as some do.”
Bride turned to look at him. Eustace was flushed and excited. His
face had grown more intent and earnest during the past months.
Bride thought that his expression was improved; but just at this
moment he was more excited than she had ever seen him before.
She wondered at the reason.
“I have come to ask a favour of your father, Bride,” he said, as they
reached the castle, and instead of passing through the gateway and
entering the hall, skirted round the building till they stood upon the
magnificent stone terrace that overhung the sea on the west side.
“Do you think he will grant it me?”
“A favour!—what favour?” asked Bride, looking wonderingly at him,
with steady fearlessness in her eyes. She was no longer shy with
him, for her instinct told her that it was not on an errand of love-
making that he had come. The last time they talked together alone
he had been seeking for her love; now he had other matters
foremost in his mind. The individual was sunk in the cause. Almost
before the words of his answer were spoken, she guessed what they
would be; yet she heard them almost with surprise.
“Bride, this next Parliament will be one that will mark an epoch in the
world’s history; I feel that I must take my share in it. I am a man
young and untried, but I feel that I can serve my country in its need. I
long to be one of its legislators in the coming struggle, which will, I
know, be a triumphant one. I have come to ask your father for the
seat which he has in his own hands. He almost offered it to me once.
Will he give it to me now, do you think, when I come to solicit it at his
hands?”
Bride’s eyes expressed a grave surprise.
“A pocket borough, as you have called them, Eustace? I thought the
system of pocket boroughs was utterly abhorrent to you—one of the
abuses which most cried for redress!”
“Yes—and I long to be one of the legislators who shall abolish the
abuse!” cried Eustace eagerly. “I would sweep all such anomalies
from the face of the earth; but to assist in the battle with all my
powers, I must be entitled for once to sit in the next Parliament.”
Bride said nothing. She looked away from Eustace over the sea, and
he saw that a shadow had fallen on her face.
“What is it, Bride?” he questioned quickly, feeling the sense of her
beauty and purity again stealing over him like a charm. He had
fancied after all these months that he could meet her without
emotion, but already he felt the old fascination creeping over him.
“I am sorry,” answered Bride gently, “I am sorry—that is all.”
“Sorry about what?” he asked quickly.
“Sorry that you feel like that—that you can stoop to such a thing.”
He started as though something had stung him.
“I do not understand you,” he said, with a certain hauteur in his tone
and a look of pain in his eyes.
She raised hers to his and looked him full in the face.
“It is not difficult to understand. You look on these pocket boroughs
as a flagrant abuse, and yet you are willing to profit by that abuse. It
is just the old story over again. You are willing to do evil that good
may come, Eustace. I do not think that good ever does come when
men have stooped to employ unworthy means. Take care you do not
ruin your own cause by making that mistake all through.”
Yes, it was the same girl he had left—the same Bride—the mystic,
the impracticable woman of dreams and theories. Beautiful ideals
are so plausible till you come to try and apply them to the sordid
realities of life—and then how untenable they become! But how was
she to know that, living in this old-world spot and in a dreamland of
her own? So he stifled his irritation and answered very patiently—
“You hardly understand, Bride. Your father will have to nominate a
member at this election, though probably for the last time. The abuse
is yet unredressed, and cannot be redressed till honest men who
love their country combine to blot it out. I wish to have the honour
and privilege of being among that number; and I am your father’s
next of kin, and the man it would be most natural for him to appoint.
It lies here; he must either give it to a man who would fight against
the good cause, though he would accept the seat without a qualm, or
it must go to one like myself, who, recognising the thing as a
manifest outrage upon constitutional representation, yet for this last
time would take advantage of a pernicious system in order to hurl it
down for ever more. I hold that mine is the right position to hold. If I
were to stand aside for a man who would take the seat and strive to
hold back the cause of reform, I should be a traitor to the cause and
to my country. I ought not to stand idly by without striving to win it for
myself.”
She made no reply; but her silence was not the silence of assent,
and he knew it. He took one or two turns upon the terrace and then
said—
“Why do you always try to take the heart out of me, Bride? I never
speak with you, but it is always the same old story. You look like one
of God’s angels from heaven; you talk like a veritable saint upon
earth; and yet you stand there as it were opposed to every effort to
raise and bless and benefit humanity—a champion for what is
tyrannous and oppressive and hateful!”
It was not often that Eustace was carried away by his ardour in this
fashion; but the excitement through which he had recently been
passing had somewhat shaken and unnerved him. Bride looked
away from him and out over the sea with one of those intense gazes
of hers which calmed him better than any words could have done.
He came up and took her hand, which she did not withdraw from his
clasp.
“Forgive me,” he said; “I spoke like a brute. I did not know what I was
saying. But, O Bride! why will not you and such as you help us? Why
will you stand aloof with pitying scorn when the world and humanity
are crying aloud for your sympathy and help?”
“Not scorn,” answered Bride gently, “not scorn; but pity—yes. I often
do feel pity for you, Eustace, because I know that you will be so
bitterly disappointed. You want to make men better and happier and
more prosperous; and more prosperous you may make them by
improved legislation. Many will be content when that is done, but you
will not. Your aim goes higher. You want to see them raised out of
their degradation—to see them ennobled and made truly better. And
you will be so bitterly disappointed! I know you will; and I pity you
often from the bottom of my heart; but indeed I do not scorn you. I
know you—and—love you far too much for that.”
She spoke with quiet fearlessness, and used the word in an
impersonal sense that Eustace could not misunderstand. He bent
forward and lifted the hand he held to his lips, and she did not shrink
away, for it was not the action of a lover, and she felt it and was not
afraid. Nor was the salute in itself altogether obsolete in those days,
though growing rarer and rarer.
“You shall teach me the knowledge in which I am lacking,” he said
ardently; but she slightly shook her head.
“I am afraid not, Eustace; I am afraid the task would be too hard. You
cannot see with my eyes, nor I with yours. You think all the way
through that the end justifies the means. I hold that no lasting good
can be, or ever has been done when unworthy and time-serving
means have been employed. A man must be pure in heart before he
can successfully fight the good fight against evil.”
“You mean that I must give up hoping to sit in Parliament?” said
Eustace hotly, unable to help applying the doctrine to the matter
most near his heart.
“No, I do not mean that. I should like to see you there; but I would
rather you fought your seat like other men, and did not profit by the
very abuse you seek to overthrow.”
“Seats are only won by wading through a sink of iniquity!” said
Eustace bitterly; and Bride was silent, her face growing sternly
sorrowful. Her heart often grew heavy within her as she realised the
terrible wickedness of the great world without.
“No seat is worth that,” she said softly; but Eustace could not agree
with her.
“We must purify legislation; we must so work that a new and perfect
system rises from the ashes of the old!” he cried, his quick
enthusiasm firing at the thought. “Men can and shall be raised. We
shall one day see the dawn of a brighter and purer day. This is but
the hour of darkness which precedes the dawn. The brightness of
the day will atone for all. You will live to see a new world yet, Bride!”
A sudden light sprang into her eyes. For a moment her face was
transfigured; but as she looked at him that light died out. She
realised how widely apart were their ideas of a new world.
CHAPTER XIV
EUSTACE’S DILEMMA
“SHE is right in theory—she is perfectly right. She holds the stronger
position. But yet I cannot give it up. One cannot live in the world, and
breathe an atmosphere so far above it as she does. The thing is not
possible. What!—go back to London—go back to my friends there,
and say that I cannot accept my kinsman’s seat, because in right
and justice he should not have it to give! What a howl of derision I
should provoke! And to have to confess that my adviser in this was a
girl years younger than myself, who had hardly left her sea-girt home
all her life—who knows no more of the world than the babe in the
nursery! Why, I should become a laughing-stock to the whole of the
town! I should never be able to face the world again. No, no, no—
such scruples are untenable. A great work has to be done, and men
are wanted of birth, energy, determination, and probity; I think I may,
without undue self-appreciation, assert that I possess all these
needful qualifications. Better men than myself have told me so. First
let us get the upper hand, and then we will see what may be done for
purifying the country and raising a higher and a better standard. If
the world would listen to such teachings as Bride’s, I will not say the
world might not be a better place; but if it will not—why, we must
needs employ tools more fitted for the work. To be deterred by such
a scruple!—no—it would be unworthy of the Cause!”
Eustace was alone in his room, dressing for dinner. His welcome
from his kinsman had been kind and cordial, and he was now
bracing himself for the discussion which must follow upon the
request he had to make. The subject had not yet been broached
between them, though he fancied that the Duke half suspected his
errand, or rather the motive which had prompted it; but hitherto the
talk had been all on public matters, and he had been relieved to find
the old man by no means so hostile in mind towards the bill as he

Instant Download PDF Prentice Halls Federal Taxation 2014 Comprehensive 27th Edition Rupert Test Bank Full Chapter

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Instant Download PDF Prentice Halls Federal Taxation 2014 Comprehensive 27th Edition Rupert Test Bank Full Chapter

Uploaded by

Copyright:

Available Formats

Prentice Halls Federal Taxation 2014

Comprehensive 27th Edition Rupert

Prentice Halls Federal Taxation 2014 Comprehensive 27th

Prentice Halls Federal Taxation 2014 Individuals 27th

Prentice Halls Federal Taxation 2014 Individuals 27th

Prentice Halls Federal Taxation 2014 Corporations

Prentice Halls Federal Taxation 2015 Comprehensive 28th

Prentice Halls Federal Taxation 2013 Comprehensive 26th

Prentice Halls Federal Taxation 2016 Comprehensive 29th

Prentice Halls Federal Taxation 2013 Comprehensive 26th

3) Brother-sister controlled groups can elect to file a consolidated tax return.

5) The election to file a consolidated return is made annually.

13) Identify which of the following statements is true.

19) Identify which of the following statements is true.

20) Identify which of the following statements is true.

21) Identify which of the following statements is true.

D) none of the above

27) Identify which of the following statements is true.

29) Which of the following statements is true?

31) Identify which of the following statements is false.

D) none of the above

34) Which of the following events is an intercompany transaction?

37) Identify which of the following statements is false.

38) Identify which of the following statements is true.

43) Identify which of the following statements is true.

45) Identify which of the following statements is true.

46) Identify which of the following statements is true.

How much of Subsidiary's loss can be carried back to last year?

Taxable Income Taxable Income

The $15,000 consolidated NOL reported in the current year

Taxable Income Taxable Income

The $9,000 consolidated NOL reported in the current year

54) Identify which of the following statements is true.

55) Identify which of the following statements is true.

Income (loss) Income (loss)

Which of the following statements is not correct?

58) Identify which of the following statements is true.

Corporation Taxable Income

Which of the following statements is correct?

Taxable Income Taxable Income

Which of the following statements is incorrect?

63) Identify which of the following statements is true.

Which one of the following statements is incorrect?

Ordinary Sec. 1231

Which of following statements is incorrect?

Which of the following statements is correct?

The affiliated group's consolidated taxable income is

What is the affiliated group's consolidated regular tax liability?

72) A consolidated return's tax liability is owed by

96) What issues determine whether an affiliated group exists?

You might also like