ISSUE QUESTIONS

1. Cable Corporation, which operates a fleet of motorized trolley cars in a resort city, is undergoing a complete liquidation. John, who owns 80% of the Cable stock, plans to continue the business in another city, and will receive the cable cars, two support vehicles, the repair parts inventory, and other tools and equipment. Peter, who owns the remaining 20% of the Cable stock, will receive a cash distribution. The corporation will incur $15,000 of liquidation expenses to break its lease on its office and garage space and cancel other contracts. What tax issues should Cable, John, and Peter consider with respect to the liquidation?

2. Parent Corporation, which operates an electric utility, created a 100%-owned corporation, Subsidiary, that built and managed an office building. Assume the two corporations have filed separate tax returns for a number of years. The utility occupied two floors of the office building, and Subsidiary offered the other ten floors for lease. Only 25% of the total rental space was leased because of the high crime rate in the area surrounding the building. Rental income was insufficient to cover the mortgage payments, and Subsidiary filed for bankruptcy because of the poor prospects. Subsidiary's assets were taken over by the mortgage lender. Parent lost its entire $500,000 investment. Another $100,000 of debts remained unpaid for the general creditors, which included a $35,000 account payable to Parent, at the time Subsidiary was liquidated. What tax issues should Parent and Subsidiary consider with respect to the bankruptcy and liquidation of Subsidiary?

3. Alpha Corporation is a holding company owned equally by Harry and Rita. They acquired the Alpha stock many years ago when the corporation was formed. Alpha has its money invested almost entirely in stocks, bonds, rental real estate, and land. Market quotations are available for all of its stock and bond investments except for 10,000 shares of Mayfair Manufacturing Corporation stock. Mayfair is privately held with 40 individuals owning all 100,000 outstanding shares. Last year, Mayfair reported slightly more than $3 million in net income. In a discussion with Harry and Rita, you find that they plan to liquidate Alpha Corporation in the next six months to avoid the personal holding company tax. What tax issues should Harry and Rita consider with respect to this pending liquidation?

Write a minimum 175-word response to each question.