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CreamCo. has 4 equal shareholders who each own 1 , 0 0 0 shares: Rebecca, an individual; Jennifer, Rebecca's daughter; CrimsonCo, a C corporation in
CreamCo. has equal shareholders who each own shares: Rebecca, an individual; Jennifer, Rebecca's daughter; CrimsonCo, a C corporation in which Rebecca and Jennifer each own ; and Norman LLP an unrelated partnership. How many shares is Jennifer considered to own for purposes of applying the substantially disproportionate test of section
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