EFG Corporation is owned 40 percent by Ed, 20 percent by Frank, 20 percent by Gene, and 20 percent by X Corporation. X Corporation is owned 80 percent by Ed and 20 percent by an unrelated party. Frank and Gene are brothers.

Answer each of the following questions about EFG under the constructive ownership rules of Section 267.

1. What is Ed’s percentage ownership? ___________ %

2. What is Frank’s percentage ownership? ___________ %

3. What is Gene’s percentage ownership? ___________ %

4. If EFG sells property to Ed for a $15,000 loss, what amount of that loss can be recognized for tax purposes?