Ante is now the administrator of
ADSP. Under her helm, members have risen to 6,000.
As with an election under [section] 338(g), a [section] 338(h) (10) election is treated as if sold for the
ADSP. Treas.
Old Target's recognized gain or loss is determined by first allocating the
ADSP to each asset, using the residual method in Treasury Regulations section 1.338-6 (reported on Form 8883).
According to Zimmerman,
ADSP aggregates and analyzes data from across the continuum of care--includ-ing electronic medical record (EMR) encounters, claims, pharmacy, lab, and other available data.
1.338-4(e) computes gain or loss on each asset in a deemed sale by reference to the aggregate deemed sale price (
ADSP) allocated to that asset.
Treasury Regulations section 1.338-6 describes the classes of acquired assets to which the total transaction purchase price, referred to as the adjusted deemed selling price (
ADSP) and as the adjusted grossed-up basis (AGUB), is allocated.
ATLAS, CEO of ARIEL CORPORATION (
ADSP), describes the company's business and its background; prospects for the industry, with positive and negative trends; competitive threats; strategic opportunities for the firm including its marketing plans and acquisition potential; management strength and organization; and the financial prospects of the firm looking forward.
1.338-4(c)(1)(i),
ADSP (4) is computed as if A and B (the selling shareholders) were required to use Old T's accounting methods and the installment method were not available: ($100,000 (5) - 0 (6) + 10,000 (7) $110,000 =
ADSP* De-linking adjusted deemed sales price (
ADSP) and adjusted grossed-up basis (AGUB);
