Use of losses. Y is a C corpora- tion that elects to become an S corporation effective January 1, 1996. On that date, Y sells Whiteacre with a basis of $0 and a value of $250,000 in exchange for a $250,000 note bearing a market rate of interest payable on January 1, 2006. Y does not make the election under section 453(d) and, therefore, reports the $250,000 gain using the installment meth- od under section 453. In the year 2006, Y has income of $250,000 on collecting the note, un- expired C year attributes of $0, loss of
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Samples: Publishing Agreement, Supplemental Contract, Supplemental Contract