Firenze Company developed a

specialized banking application software program that it licenses to various financial institutions through multiple-year agreements. On January 1, 2018, these licensing agreements have a fair value of $752,500 and represent Firenze’s sole asset. Although Firenze currently has no liabilities, the company has a $205,000 net operating loss (NOL) carryforward because of recent operating losses.

On January 1, 2018, Parma, Inc., acquired all of Firenze’s voting stock for $960,000. Parma expects to extract operating synergies by integrating Firenze’s software into its own products. Parma also hopes that Firenze will be able to receive a future tax reduction from its NOL. Assume an applicable federal income tax rate of 35 percent.

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