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Boots Inc. is owned equally by Alfonso and his daughter Nancy, each of whom holds 1,000 shares in Boots. Alfonso wants to retire from the company, and it is decided that Boots will redeem all 1,000 of Alfonso’s shares for $25,000 per share on December 31 of this year. Alfonso’s tax basis in each share is $500. Boots Inc. has current E&P of $1,000,000 and accumulated E&P of $5,000,000.
Assume that as traffic density increases along a given stretch of road, there comes a point when traffic begins to slow down. The following table gives the times taken for a car to travel the stretch of road (in minutes) according to the number of cars entering the road per minute. Cars entering the road 5 6 7 8 9 10 11 Journey time 10 10 11 13 16 22 30 (a) Copy out the table and add the following rows: (i) total journey time for all cars; (ii) extra journey time as traffic increases by one more car (marginal social time cost); (iii) additional time cost imposed on other road users for each additional car entering the road (marginal external time cost). (See Table 13.3 in the text.) (b) Assume that time is valued at 10p per minute. On a graph, plot the marginal private time cost (journey time) and the marginal social time cost. (c) Assume that electronic road pricing is introduced. What charge should be levied when traffic density reaches (i) 6 cars per minute; (ii) 8 cars per minute; (iii) 11 cars per minute? (d) What additional information would you need in order to work out the socially efficient traffic density on this particular stretch of road?
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In a §351 exchange, how does the tax treatment differ in cases where liabilities are assumed with a tax-avoidance purpose versus where liabilities assumed exceed basis?
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