Suppose you are a CPA, and you have a corporate client that has been operating for several years. The company is considering expansion through reorganizations. The company currently has two (2) subsidiaries acquired through Type B reorganizations. The client has asked you for tax advice on the benefit of a Type A, C, or D reorganization over a Type B reorganization. Additional facts regarding the issues are reflected below.  The company currently files a consolidated income tax return with the two (2) subsidiaries acquired through a Type B reorganization.  ABC Corporation, a subsidiary targeted by the client for takeover, has substantial net operating losses.  XYZ Corporation and BB Corporation will be acquired as subsidiaries in the next six (6) months. Use the Internet and Strayer databases to research the rules and income tax laws regarding Types A, B, C, and D reorganizations and consolidated tax returns. Be sure to use the six (6) step tax research process in Chapter 1 and demonstrated in Appendix A of your textbook as a guide for your written response. Write a four to six (4-6) page paper in which you: 1. Compare the long-term tax benefits and advantages of each type of reorganization, and recommend the type of reorganization that will be most beneficial to the client. 2. Suggest the type of reorganization the client should use for the ABC Corporation based on your research. Justify the response. 3. Propose a taxable acquisition structure for the client’s planned acquisitions over a nontaxable reorganization. Assess the value of a taxable transaction over a nontaxable reorganization for the client. 4. Examine the value and limitations of including the ABC Corporation if acquired as a wholly owned subsidiary in the consolidated return, and provide a recommendation to your client. Support the recommendation with applicable research. 5. Create a scenario that will allow the client to reduce any disadvantages from filing a consolidated return as a member of a controlled group. 6. Use the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

I am looking for help with a discussion post in response to this.. something plain and simple…

Sometimes Reconstruction gets short shrift, but there is a proper historiographical debate concerning the twelve years following the Civil War. Eric Foner has talked about how Reconstruction represented a “splendid failure” because it offered African Americans a vision of how a free society should function (albeit temporarily). Therefore, Reconstruction gave African Americans something to which they could aspire in the subsequent Civil Rights movements. Other historians argue that Reconstruction was not a “splendid failure” so much as it was just a failure. They argue that the simple fact is that any political leader (even Lincoln had he survived) could not have managed to secure permanent political, economic, and social gains for former slaves. That being said, whether a splendid failure or simply a failure, Reconstruction contributed to the secondary status of African Americans (and resolving that status represents one of the key threads running through the second half of American History).

What do you believe: Was Reconstruction a “splendid failure” or just a failure? How can we measure success or failure in this situation?