What would be the primary benefit to Zena

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Question - Now assume Delrey, Inc. is a wholly owned subsidiary of Monterrey, Inc. Purchase price has been negotiated to the same as in #1 (Property with an adjusted $500,000 and FMV of $3,000,000 and Cash of $20,000,000. Zena and Delrey consent to a IRC Section 338(h)(10) election. Monterrey's basis in Delrey is $13,000,000. On July 1, 2019 Zena, Inc. Purchased the stock of Delrey, Inc. directly from Monterrey, Inc. Zena consummated the purchase using cash of $20,000,000 and property with an adjusted basis of $500,000 and a Fair Market value of $3,000,000. At the time of the acquisition, Delrey had the following assets:

Assets

Adjusted basis

FMV

AR

400,000

300,000

Marketable securities

300,000

800,000

Loan receivable

200,000

100,000

US GOV Securities

500,000

500,000

Inventory

1,000,000

2,000,000

Furniture/fixtures

0

1,100,000

Building

600,000

4,000,000

Covenant not to compete

0

1,200,000

Total

3,000,000

10,000,000

Required - What would be the primary benefit to Zena from the IRC Section 338 election?

Reference no: EM133076302

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