Question
A, B and C, who are unrelated, each own 1,000 shares of common stock (the only class outstanding) of X Corporation with a fair market
A, B and C, who are unrelated, each own 1,000 shares of common stock (the only class outstanding) of X Corporation with a fair market value of $400 per share. X has $600,000 of accumulated and no current earnings and profits. A and C each have $50,000 adjusted basis in their X stock. B, who recently received her stock as an inheritance, has a $400,000 adjusted basis. B wishes to retire and dispose of her stock. What are the tax consequences of the following alternative transactions
1. Pursuant to a cross-purchase buy-sell agreement, B sells 500 shares each to A and C for $200,000 each.
2. Pursuant to an entity-purchase buy-sell agreement, X redeems all of B's stock for $400,000.
3. Same as (1), above, except the agreement required A and C to buy B's stock over ten years, with appropriate interest, but they did not have sufficient funds to make the payments so they caused X to make them on their behalf.
4. A and C had options to buy B's stock when B retired but they were short of funds and allowed X to redeem the stock instead.
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