Problem
Parent Corporation purchased 75 percent of Subsidiary Corporation in 2000; Subsidiary's current balance sheet shows the following figures:
Basis Value
Demand Deposit $20,000 $20,000
IBM Stock $30,000 $50,000
Parking Lot $5,000 $30,000
Building 0 $100,000
Mortgage ($15,000) ($15,000)
Subsidiary has a net operating loss carryover in 2006 of $7,000 and earnings and profits of $22,000. The subsidiary redeemed in 2003 the 25% shareholder Roy Rogers. The Subsidiary distributed the IBM stock for his 25% interest. In 2006, Subsidary adpots a plan of liquidation.
What happens to Subsidiary's NOL and E&P?