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A owns 50 X Corp. common shares with an adjusted basis of 20,000. B owns 50 X common shares with an adjusted basis of 75,000.

A owns 50 X Corp. common shares with an adjusted basis of 20,000. B owns 50 X common shares with an adjusted basis of 75,000. X has earnings and profits of 30,000 accumulated as of the end of the prior year. For the current year, X has taxable income of 85,000 just from operations. IN ADDITION, X has received IBM dividends of 10,000. Also (in addition to the operating income), note that X has engaged in a like-kind exchange in which X had a realized gain of 35,000 and a recognized gain of 0. Also (in addition to operating income) note that X has an net operating loss deduction in the current year (carried from a prior year) of 15,000. X distributes 100,000 to each A and B (i.e. A receives 100,000 and B receives 100,000). Describe all of the consequences to all of the parties.

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