Jersey Corporation purchased 50% of Target Corporation's single class of stock on June 1 of this year. They purchased an additional 40% on November 20 of this year. The Sec. 338 election must be made on or before

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The Sec. 338 election allows a purchasing corporation to treat a qualified stock purchase as an asset acquisition for tax purposes. The election must be made by the 15th day of the 9th month following the month in which the acquisition occurred. Since the additional purchase that resulted in an 80% ownership occurred on November 20, the deadline for making the Sec. 338 election would be August 15 of the following year.

Jersey Corporation Purchased 50% of Target Corporation's Single Class of Stock