NEW YORK (TheStreet) -- Yahoo! (YHOO) shares are rallying 3.12% to $28.49 in early morning trading on Tuesday after the company said it would move ahead with the spin off of its stake in Chinese e-commerce company Alibaba (BABA) - Get Report despite the IRS declining to rule that the transaction would be tax free, Reuters reports. 

Yahoo! is forecasting the spin off to be completed during the fourth quarter.

TheStreet's Jim Cramer, Portfolio Manager of the Action Alerts PLUS Charitable Trust Portfolio commented on Yahoo!'s spin off plan saying: "To think that Yahoo is worth nothing ex spin is moronic. They have huge pageviews. I continue to think that you should be long Yahoo against Alibaba."

In 2005, Yahoo! paid $1 billion for a 40% stake in Alibaba. Now, the stake in Alibaba is worth $22.75 billion, according to Reuters

However, one risk is that the transaction could carry up to $9 billion in taxes, Quartz added. 

Separately, TheStreet Ratings team rates YAHOO INC as a Hold with a ratings score of C+. TheStreet Ratings Team has this to say about their recommendation:

We rate YAHOO INC (YHOO) a HOLD. The primary factors that have impacted our rating are mixed, some indicating strength, some showing weaknesses, with little evidence to justify the expectation of either a positive or negative performance for this stock relative to most other stocks. The company's strengths can be seen in multiple areas, such as its revenue growth, largely solid financial position with reasonable debt levels by most measures and notable return on equity. However, as a counter to these strengths, we also find weaknesses including unimpressive growth in net income, weak operating cash flow and a generally disappointing performance in the stock itself.

Highlights from the analysis by TheStreet Ratings Team goes as follows:

  • YHOO's revenue growth has slightly outpaced the industry average of 7.1%. Since the same quarter one year prior, revenues rose by 14.7%. This growth in revenue does not appear to have trickled down to the company's bottom line, displayed by a decline in earnings per share.
  • Although YHOO's debt-to-equity ratio of 0.04 is very low, it is currently higher than that of the industry average. Along with this, the company maintains a quick ratio of 4.84, which clearly demonstrates the ability to cover short-term cash needs.
  • The gross profit margin for YAHOO INC is currently very high, coming in at 70.85%. Regardless of YHOO's high profit margin, it has managed to decrease from the same period last year. Despite the mixed results of the gross profit margin, YHOO's net profit margin of -1.73% significantly underperformed when compared to the industry average.
  • The company, on the basis of change in net income from the same quarter one year ago, has significantly underperformed when compared to that of the S&P 500 and the Internet Software & Services industry. The net income has significantly decreased by 108.0% when compared to the same quarter one year ago, falling from $269.71 million to -$21.55 million.
  • Net operating cash flow has decreased to $307.95 million or 13.83% when compared to the same quarter last year. In addition, when comparing the cash generation rate to the industry average, the firm's growth is significantly lower.
  • You can view the full analysis from the report here: YHOO