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QUESTION
Highway Corporation has net assets valued at $800,000 and an NOL of $250,000.
Highway Corporation has net assets valued at $800,000 and an NOL of $250,000. On September 30 of the current year, Highway is acquired by Plum Corporation, a calendar year taxpayer, in a restructuring qualifying as a tax-free reorganization. Highway shareholders receive 30% of Plum's shares in exchange for all of their Highway stock. Assuming that the Federal long-term tax-exempt rate is 8%, what is the maximum amount of Highway's NOL available to Plum in the current year?
