QUESTION 21
Corporation Z distributes in kind its long held Apple stock with an adjusted basis of $480 and a fair market value of $200 to shareholder C. Corporation Z also distributes Apple stock with an adjusted basis of $120 at a fair market value of $200 to shareholder D.
a. |
Corporation Z does not have loss on the distributions. |
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b. |
The distributions to C will reduce E&P by $480 (but not create negative E&P). |
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c. |
Corporation Z realizes gain of $80 on the distribution of the property and that amount less accrued income tax is added to E&P. |
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d. |
All of the above. |
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e. |
None of the above. |
QUESTION 22
Corporation Z is owned entirely by two individuals, C and D. C owns 60 shares of Z common stock bought in one transaction for $1,200. D owns 40 shares of Z common stock with a basis of $60 per share. The stock’s fair market value is $40 per share. Z’s E&P is $1,000. C sells 60 shares to Z for $1,800. The following statements are with regard to C.
a. |
The redemption will be given dividend treatment. |
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b. |
The redemption will be given sale treatment under 302(b)(3), complete termination of interest. |
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c. |
It is impossible to tell whether the transaction will be given sale or dividend treatment. |
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d. |
None of the above. |
QUESTION 23
Corporation Z is owned entirely by two individuals, C and D. C owns 60 shares of Z common stock bought in one transaction for $1,200. D owns 40 shares of Z common stock with a basis of $60 per share. The stock’s fair market value is $40 per share. Z’s E&P is $1,000.C sells 20 shares to Z for $800. The following statements are with regard to C.
a. |
The redemption will be given dividend treatment. |
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b. |
The redemption will be given sale or exchange treatment under 302(b)(2), substantially disproportionate disposition. |
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c. |
It is impossible to tell whether the transaction will be given sale or dividend treatment. |
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d. |
The redemption will most likely be treated as a sale under 302(b)(1), not essentially equivalent to a dividend, since the voting percentage has dropped to 50 percent in a two-person corporation and this is usually sufficient to meet the test. |
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e. |
None of the above. |
QUESTION 24
Corporation Z is owned entirely by two individuals, C and D. C owns 60 shares of Z common stock bought in one transaction for $1,200. D owns 40 shares of Z common stock with a basis of $60 per share. The stock’s fair market value is $40 per share. Z’s E&P is $1,000. D sells 10 shares back to Z for $400. The following statements are with regard to D.
a. |
The redemption will be treated as a dividend. |
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b. |
The redemption will be treated as a sale under 302(b)(2), substantially disproportionate disposition. |
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c. |
It is impossible to tell how the redemption will be treated. |
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d. |
The redemption will likely be treated as a sale under 302(b)(1), not essentially equivalent to a dividend. |
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e. |
None of the above. |
QUESTION 25
Corporation Z is owned entirely by two individuals, C and D. C owns 60 shares of Z common stock bought in one transaction for $1,200. D owns 40 shares of Z common stock with a basis of $60 per share. The stock’s fair market value is $40 per share. Z’s E&P is $1,000. C sells 60 shares to Z for $1,800. Additionally, C and D for this question are father and son.
a. |
There will be attribution under Section 318, so that no matter how many shares C sells to Corporation Z, by attribution he will own 100% of the outstanding shares afterwards. |
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b. |
There will be attribution under 318 if C's father is living since there is double attribution through C's father. |
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c. |
There is no attribution. |
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d. |
None of the above. |
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