Through a “Type A” reorganization, VizslaCo acquires 100% of Puli Corporation by exchanging 30% of its stock for all of Puli’s assets and liabilities. The VizslaCo. stock was exchanged for all of the Puli shareholders. Then Puli liquidated. The net value of Puli’s assets at the time of the restructuring was $500,000, and the Federal long-term tax-exempt rate was 5%. Puli held business tax credit carryovers of $61,250. If VizslaCo is always in the 35% tax bracket, what is the value of these credits to VizslaCo., assuming that it uses a discount rate of 8%?
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