a. Since Silver Fox is insolvent, all of its assets will go toward its debts, leaving nothing for Randall.

Randall will not recover any of his basis in the stock. Since the stock was not acquired from the corporation on original issuance, the stock does not qualify as Sec. 1244 stock. Thus, Randall suffers a $250,000 long-term capital loss. b. The stock is qualified Sec. 1244 stock since it is original issue stock. Since Randall is single, the loss will consist of $50,000 ordinary loss and $200,000 long-term capital loss. c. Since at least 80% of the voting power of Silver Foxs stock is owned by Randall Corporation, and more than 90% of Silver Foxs gross receipts are from its business operation, the $250,000 loss is all ordinary. d. Since at least 80% of the voting power of Silver Foxs stock is owned by Randall Corporation, and more than 90% of Silver Foxs gross receipts are from its business operation, the $250,000 loss is all ordinary.