Silverbell Corp. purchases all of Sparkleberry Inc.’s stock…
Silverbell Corp. purchases all of Sparkleberry Inc.’s stock for $610,000 cash. Silverbell makes a timely Sec. 338 election. Sparkleberry’s balance sheet at the close of business on the acquisition date is as follows: Assume the equipment cost $400,000, and the building is MACRS property on which Sparkleberry has claimed $30,000 of depreciation. What is the aggregate deemed sale price (ADSP) for the Sparkleberry assets? What amount and character of gain or loss must Sparkleberry recognize for each asset on the deemed sale? What is the adjusted grossed-up basis for the Sparkleberry stock, and what basis is allocated to each asset?