1. How is the February 1" distribution taxed to Heath, Jetta, and Ashley? Please use the table below. Capital Gain February 1" Distribution Percent Dividend Ownership (from current E&P) Reduction in Basis Dividend (from accumulated E&P) Heath Jetta Ashley 60% 20% 20% 2. How is the June 1" distribution taxed to Heath? Please use the table below. Also, why doesn't 1.R.C. $ 302(b)(1) or 5 302(b)(2) apply to her redemption? June 1" Dividend Dividend Reduction in Capital Gain Distribution (from (from Basis current E&P) accumulated E&P) Heath 3. How is the September 14 distribution taxed to Heath, Jetta, Petra, and Ashley? Please use the table below September 1" Distribution Capital Gain Percent Dividend Ownership (from Dividend (from Reduction in Basis current E&P) accumulated E&P) Heath Jetta Ashley Petra 4. How is the October 1" distribution taxed to Heath (please indicate amount of taxable income and how it is taxed)? Please use the table below. Also, why doesn't I.R.C. 9 302(b)(1) or 302(b)(2) apply to her redemption? October 1" Dividend Dividend Reduction in Capital Gain Distribution (from current (from Basis E&P) accumulated E&P) Heath 5. What is Petra's gain realized and gain recognized upon the contribution of the automobile in exchange for 10 shares of Lux Corp.? Does non-recognition treatment under 1.R.C.5 351 apply? Does Lux Corp. realize or recognize any gain upon the issuance of 10 shares to Petra? What is the relevant Code section which sets forth the rule? 6. What is Lux's Corp gain (or loss) realized and gain (or loss) recognized upon (1) the sale of the automobile; and (ii) the distribution of the condo? 7. How is the November 1" distribution taxed to Jetta? Please use the table below. Also, why doesn't I.R.C. $ 302(b)(1) or $ 302(b)(2) apply to her redemption? November 1" Dividend Dividend Reduction in Capital Gain Distribution (from current (from Basis E&P) accumulated E&P) Jetta a 8. Is the 2016 merger between Prowess Corp. and Lux Corp. a "tax-free" reorganization under LR.C. S 368? Why/Why not? 1. How is the February 1" distribution taxed to Heath, Jetta, and Ashley? Please use the table below. Capital Gain February 1" Distribution Percent Dividend Ownership (from current E&P) Reduction in Basis Dividend (from accumulated E&P) Heath Jetta Ashley 60% 20% 20% 2. How is the June 1" distribution taxed to Heath? Please use the table below. Also, why doesn't 1.R.C. $ 302(b)(1) or 5 302(b)(2) apply to her redemption? June 1" Dividend Dividend Reduction in Capital Gain Distribution (from (from Basis current E&P) accumulated E&P) Heath 3. How is the September 14 distribution taxed to Heath, Jetta, Petra, and Ashley? Please use the table below September 1" Distribution Capital Gain Percent Dividend Ownership (from Dividend (from Reduction in Basis current E&P) accumulated E&P) Heath Jetta Ashley Petra 4. How is the October 1" distribution taxed to Heath (please indicate amount of taxable income and how it is taxed)? Please use the table below. Also, why doesn't I.R.C. 9 302(b)(1) or 302(b)(2) apply to her redemption? October 1" Dividend Dividend Reduction in Capital Gain Distribution (from current (from Basis E&P) accumulated E&P) Heath 5. What is Petra's gain realized and gain recognized upon the contribution of the automobile in exchange for 10 shares of Lux Corp.? Does non-recognition treatment under 1.R.C.5 351 apply? Does Lux Corp. realize or recognize any gain upon the issuance of 10 shares to Petra? What is the relevant Code section which sets forth the rule? 6. What is Lux's Corp gain (or loss) realized and gain (or loss) recognized upon (1) the sale of the automobile; and (ii) the distribution of the condo? 7. How is the November 1" distribution taxed to Jetta? Please use the table below. Also, why doesn't I.R.C. $ 302(b)(1) or $ 302(b)(2) apply to her redemption? November 1" Dividend Dividend Reduction in Capital Gain Distribution (from current (from Basis E&P) accumulated E&P) Jetta a 8. Is the 2016 merger between Prowess Corp. and Lux Corp. a "tax-free" reorganization under LR.C. S 368? Why/Why not
