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1) Jackson operates a stock brokerage. He paid the Chief Financial Officer of Nextel $500,000 for information regarding the pending merger of Nextel and Sprint.
1) Jackson operates a stock brokerage. He paid the Chief Financial Officer of Nextel $500,000 for information regarding the pending merger of Nextel and Sprint. Jackson received material non-public information from the CFO of Nextel and, in the process, violated numerous criminal and civil statutes. The SEC investigated Jackson and fined him $2,500,000. In connection with the SEC probe, Jackson hired legal counsel. His attorney's fees totaled $375,000. His attorney was also his brother. The fees paid to his brother were not reasonable. His brother would ordinarily only charge $100,000 for the legal work Jackson received - Jackson paid extra just because it was his brother. What amounts (if any) can Jackson deduct as an ordinary and necessary business expense. 2) Banana Company reports current year E&P of $1,300,000 and accumulated E&P at the beginning of the year of $1,200,000. Banana Company distributed $3,400,000 to its shareholders on the last day of the year. Tax basis in her Banana stock before the distribution is $500,000. a) How much of the $3,400,000 distribution is treated as a dividend? b) What is the tax basis in Banana Company stock after the distribution (assume a single. shareholder owns all stock)? cl What is Banana Company's accumulated E&P on the first day of next year? Inser
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