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Axle Corporation was formed in 1995. It is based in Iowa and operates throughout the US Midwest. Axle is owned by the Miller family, one-third each by sister Midge (age 38), sister Trudy (age 51), and brother Jack (age 45). The company controls about $250 million in productive and investment assets, most of which are located in Iowa.
Problem 1: Consider the alternative of complete liquidation of Axle. A complete liquidation of Axle would be followed by a cash purchase of the distribution division by the Cooke group, and of the corporate and manufacturing assets by the Millers. What are the tax consequences to all the parties involved?
Problem 2: Consider either a Type A or Type C reorganization. What are the tax consequences to all the parties involved?
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