Priv. Ltr. Rul. 201115001 (Jan. 4, 2011)

(corporate taxpayer acquired stock of subsidiary at time subsidiary was insolvent and subsidiary's stock became worthless; taxpayer had no excess loss account in subsidiary's stock and made no distributions to taxpayer that caused the insolvency; conversion qualified as identifiable event for purposes of I.R.C. Sec. 165; taxpayer could claim worthless stock loss under I.R.C. Sec. 165(g)).