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Section 338 Election and an Inventory Sale
Harrison Corporation, a C corporation, is part of a consolidated group, with assets consisting of inventory with a pre-transaction tax basis of $3,200 and value of $40,000. Harrison also has $3,200 of liabilities. Debra Smith acquires 100% of Harrison's outstanding stock for $36,800, and the parties make a Sec. 338(h)(10) election.
Prepare a letter to Debra that answers the following questions:
Question 1: What is Harrison Corp.'s adjusted grossed-up basis (AGUB)?
Question 2: What is the inventory's allocated tax basis?
Question 3: How much gain will be realized when the inventory is sold?
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