Parent basis in its Subsidiary stock is $200,000, which corresponds to the $200,000 common stock on Subsidiary balance sheet.
The $1 million note payable on Subsidiary balance sheet is payable to Parent and corresponds to the note receivable on Parent balance sheet.
The corporations do not file consolidated tax returns.
Subsidiary has $600,000 of net operating loss (NOL) carryovers.
The FMV and adjusted basis of Subsidiary assets are the same amount.
Just prior to the liquidation, Subsidiary uses $150,000 of its assets to pay off its general liabilities.
Subsidiary transfers all its assets and liabilities to Parent upon a complete liquidation.
Determine the tax consequences to Parent and Subsidiary upon Subsidiary liquidation.