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( 1 ) Carol owns 4 , 0 0 0 shares of the stock of ABC Corporation. In 2 0 1 9 , in exchange

(1) Carol owns 4,000 shares of the stock of ABC Corporation. In 2019, in exchange for some of her shares, Carol receives a check for $400,000. Her basis in her entire interest in ABC Corp was equal to $1,000,000, and her adjusted basis of the exchanged shares is equal to $250,000. ABC had $1,200,000 of Earnings & Profits as of the end of the 2019 tax year. In 2018, Carol sustained stock market losses equal to $175,000 and has a LTCL carryover to 2019 equal to $172,000.
(a) Assuming she has no other items of income or loss in 2019 and does not itemized her deductions, what are the tax consequences to Carol if the redemption of her shares does not qualify for sale or exchange treatment under 302?
(b) Assuming she has no other items of income or loss in 2019 and does not itemized her deductions, what are the tax consequences to Carol if the redemption of her shares does qualify for sale or exchange treatment under 302?
(2) DEF Corporation has 10,000 shares of voting common stock outstanding. Ann owns 7,000 shares and Ben owns 3,000 shares. Ann and Ben attended the same college, but they are not related. Which of the following transactions would constitute a redemption satisfying the requirements of 302(a):
(a) DEF Corporation acquires 3,200 shares from Ann
(b) DEF Corporation acquires 4,000 shares from Ann
(c) DEF Corporation acquires 1,000 shares from Ben.
(d) DEF Corporation acquires 5,100 shares from Ann and 1,000 shares from Ben at the same time.
(e) Assume that DEF acquired 4,200 shares from Ann and nine (9) months later redeemed 1,800 shares from Ben.
(3) XYZ Corporation redeems a portion of its stock owned by one of its shareholders, Black. The corporation redeems Black's shares by distributing to him a parcel of real property with a FMV of $420,000 and an adjusted basis in the hands of XYZ Corporation of $245,000. What is the amount of gain, if any; XYZ Corporation will recognize that under the following circumstances?
(a) The redemption fails to satisfy any of the tests of 302(b) and therefore fails to fit within the provisions of 302(a) and is required to be tested under 301?
(b) The redemption satisfies the test set forth in 302(b)(2) and therefore does fit within the provisions of 302(a).
(4) Two unrelated individuals, Aaron & Burr, own the stock of ABC Corporation. ABC redeems all of Aaron's stock in a transaction that fits within the provisions of 302(a). ABC had earnings and profits equal to $80,000. The corporations assets have a fair market value equal to $400,000 and liabilities equal to $280,000.
(a) What is the proper amount, if any, of the reduction of ABCs earnings and profits if Aaron received a $60,000 check in exchange for her ABC stock?
(b) What is the proper amount, if any, of the reduction of ABCs earnings and profits if the corporations assets were worth $340,000, and Aaron received $30,000 in exchange for his X Corporation stock?

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