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In selling multiple assets, the sales price should be contractually allocated among each asset to determine the taxable gain or tax loss from the sale of each asset, as well as the aggregate net taxable gain or tax loss This allocation may impact the seller s tax liability, depending on the character of each of the assets sold for income tax purposes and the amount allocated to each of the assets To the extent that certain assets are subject to transfer taxes, the allocation may also affect the amount of transfer taxes due by either allocating more or less value to such assets Usually, the buyer will have different objectives than the seller with respect to a sales price allocation This is known as tax polarity, and where it exists between a buyer and a seller, a sales price allocation agreed to by them normally will be respected by the IRS and the courts To the extent justifiable under the facts and circumstances, the general rule for sellers is



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4 A node appears in the left pane, and we click on the plus symbol to unfold it to reveal the base objects under the root of the directory 5 Finally we double-click the CN=Users and CN=Builtin containers They will unfold to enumerate all the users and all the built-in groups on the server, respectively The Users container is displayed in Figure 3-4





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Because the only <INPUT>tags within the table are the check boxes themselves, and they are only present within the TBODY, the code can take advantage of this fact to work backward to find the corresponding TR for the menu item The function loops over each check box tag, gets its parent <TR> tag using the getParentTag() method, and then retrieves the child <TD> tag corresponding to where the price information is kept The text string within the <TD> tag is always formatted as a floating-point number, so the code can call the parseFloat() function on the child text node s data property to get a floating-point number (this, of course, is usually not the case in real life, and the text would probably require some further processing to get the numerical representation):

3:

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to allocate value to each of the following types of assets up to, but not in excess of, their adjusted tax basis: Noncapital assets, whose sale for more than their adjusted tax basis would give rise to ordinary income Capital assets that have been held for one year or less at the time of the sale, the sale of which for more than their adjusted tax basis would give rise to short-term capital gain Assets that have been subject to prior depreciation or amortization deductions, the sale of which requires the prior depreciation and amortization deductions to be recaptured by the seller as ordinary income to the extent the value allocated to them exceeds their adjusted tax basis

for (i=0; i < aCBTagslength; i++) { if (aCBTags[i]checked) { // get the checkbox' parent TR var oTR = getParentTag(aCBTags[i],'TR'); // retrieve the price from the TD var oTDPrice = oTRgetElementsByTagName('TD')[2]; // the child text node contains the price

Figure 3-4

The Active Directory Administration Tool, ldpexe, enumerates Active Directory users and groups via an authenticated connection

Any remaining sales price could then be allocated to capital assets held for more than one year, such as goodwill (which may now be amortized for income tax purposes over a 15-year period), the sale of which would result in long-term capital gains The buyer, on the other hand, generally would want as much value as possible allocated to assets that have the shortest possible depreciable or amortizable lives (ie, assets with lives less than the 15-year life of goodwill) for income tax purposes, so that it may recapture a portion of the purchase price as soon as possible through depreciation and amortization deductions The buyer generally would also prefer to allocate full retail value to inventory (a noncapital asset) rather than just the seller s adjusted tax basis in the inventory, in order that the buyer not have any taxable income upon sale of the inventory These differing objectives can cause some tension in the negotiations, particularly depending on the relative bargaining power of the parties, but willing buyers are usually accommodating

fBillTotal += parseFloat(oTDPricefirstChilddata); } } return Mathround(fBillTotal*1000)/1000; }

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