ENP Corporation is a calendar-year C corporation. The year 2018 is ENP's first year in business. It is currently September 1, 2021 but ENP has not yet filed its 2020 tax return and will likely extend its filing. ENP has made (or will make) the following dividend distributions:

2020 2021

February 15 $ 40,000 $ 60,000

May 15 40,000 60,000

August 15 40,000 60,000

November 15 40,000 60,000

Required:

A. If the IRS asserts the accumulated earnings tax for 2020, what is the maximum dividend paid deduction ENP could claim taking into account the above items and any other mechanisms in the law? Assume that ENP's accumulated taxable income before the dividends paid deduction but after the accumulated earnings credit is $500,000. Also assume that ENP will make any necessary elections. Explain.

B. Alternatively, if the IRS asserts the personal holding company tax for 2020, what is the maximum dividend paid deduction ENP could claim taking into account the above items and any other mechanisms in the law relating to the dividends paid deduction? Assume that ENP's undistributed personal holding company income before any dividends paid deduction is $500,000. Also assume that ENP will make any necessary elections in computing its available dividends paid deduction. Explain.