Question
Ann owns all of the common stock (the only class outstanding) of Pelican Corporation. Prior to the transactions below and as a result of a
Ann owns all of the common stock (the only class outstanding) of Pelican Corporation. Prior to the transactions below and as a result of a Section 351 transfer, Ann has a $10,000 basis in her Pelican stock. What result to Ann and Pelican in each of the following alternative situations?
(a) In Year One, Pelican has $5,000 of current and no accumulated earnings and profits and it distributes $17,500 to Ann.
(b) Pelican has a $15,000 accumulated deficit in its earnings and profits at the beginning of Year Two. In Year Two Pelican has $10,000 of current earnings and profits and it distributes $10,000 to Ann.
(c) Pelican has $10,000 of accumulated earnings and profits at the beginning of Year Two and $4,000 of current earnings and profits in Year Two. On July 1 of Year Two, Ann sells half of her Pelican stock to Baker Corporation for $15,000. On April 1 of Year Two, Pelican distributes $10,000 to Ann, and on October 1 of Year Two, Pelican distributes $5,000 to Ann and $5,000 to Baker.
(d) Same as (c), above, except that Pelican has a $10,000 deficit in earnings and profits in Year Two as a result of its business operations.
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