Question
Corporation Z is owned entirely by two individuals, C and D. C owns 60 shares of Z common stock bought in one transaction for $1,200.
Corporation Z is owned entirely by two individuals, C and D. C owns 60 shares of Z common stock bought in one transaction for $1,200. D owns 40 shares of Z common stock with a basis of $60 per share. The stocks fair market value is $40 per share. Zs E&P is $1,000. C sells 60 shares to Z for $1,800. Additionally, C and D for this question are father and son.
a. | There will be attribution under Section 318, so that no matter how many shares C sells to Corporation Z, by attribution he will own 100% of the outstanding shares afterwards. | |
b. | There will be attribution under 318 if C's father is living since there is double attribution through C's father. | |
c. | There is no attribution. | |
d. | None of the above. |
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