Question
10. Seven years ago, Eleanor transferred property she had used in her sole proprietorship to Blue Corporation for 1,000 shares of Blue Corporation in a
10. Seven years ago, Eleanor transferred property she had used in her sole proprietorship to Blue Corporation for 1,000 shares of Blue Corporation in a transaction that qualified 351. The assets had a tax basis to her of $400,000 and a fair market value of 2,000,000 on the date of the transfer. In the current year, Blue Corporation with E&P of $1 million, redeems 800 shares from Eleanor for $1675,000. Required: a. Does the Redemption transaction qualify for sale/exchange treatment under IRC 302 (b)(1)? Why/Why not? b. Does the Redemption transaction qualify for sale/exchange treatment under IRC 302 (b)(2)? Why/Why not?
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