Question
ABC Company is owned equally by Jeff and Alex (unrelated taxpayers), each of whom own 2,500 shares in the company (5,000 shares outstanding). On December
ABC Company is owned equally by Jeff and Alex (unrelated taxpayers), each of whom own 2,500 shares in the company (5,000 shares outstanding). On December 31, 2020, ABC redeemed 1,500 of Jeff's shares for $500,000 in a transaction qualifying as a "Substantially Disproportionate Redemption". ABC has current E&P of $400,000 and accumulated E&P of $800,000 (computed without regard to the stock redemption). Assuming ABC did not make any dividend distributions during 2020, by what amount does the company reduce its total E&P (current and accumulated combined) as a result of the redemption?
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