Buyer and seller allocation of purchase price as, for example, an asset or 338 transaction; IRC Section 1060; GAAP treatment related to structuring and purchase price allocation; Section 1231 gains such as: goodwill, land, and other assets with fair market values higher than original tax cost; Section 197 issues such as: short-lived assets including machinery and equipment, inventory, prepaid expenses, etc. • Post-Transaction Filing Elections and Requirement such as: Adjusting or selecting different tax elections and accounting periods and methods; Year-end conformity with affiliated companies' year-ends and "short-period" returns; Responsibility for the pre- and post-acquisition income tax, payroll tax, property tax and other filings.