Question
As of January 1, Year One, Lion Corporation is owned by two individuals, Tiger and Redwing (who are unrelated unless otherwise stated). Lion Corporation has
As of January 1, Year One, Lion Corporation is owned by two individuals, Tiger and Redwing (who are unrelated unless otherwise stated). Lion Corporation has 200 shares outstanding held as follows: Tiger owns 80 shares of the only class of Lion Corp. common voting stock; Tiger purchased these shares ten years ago for $24,000. Redwing owns the other 120 shares of the only class of Lion Corp common voting stock. Redwing purchased these shares 5 years ago for $12,000. Lion Corp. accumulated E&P is $1,000 on January 1, Year One.
Part 1. Assume during Year One, Tiger sells 60 shares back to Lion for $12,000. Three days later, (still in Year One) Redwing sells 20 shares back to Lion Corp. for $4,000 pursuant to an agreement reached with Lion Corporation the prior year. What is the tax effect of these transactions to Tiger, Redwing and Lion Corporation? For purposes of your answer, ignore the potential application of IRC Section 302(b)(1).
Part 2. Assume all the facts of (a) above except that Tiger sold 22 shares, rather than 60 shares, back to Lion Corporation for $4,400. What is the tax effect of these transactions to Redwing, Tiger and Lion Corporation? For purposes of your answer, ignore the potential application of IRC Section 302(b)(1).
Part 3. Assume the only transaction in Year One is Redwing sells 60 shares back to Lion Corp for $12,000. What is the tax effect of this transaction to Redwing? For purposes of your answer, ignore the potential application of IRC Section 302(b)(1).
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