Fact Pattern.

On January 1 of Year one Ant and Bee formed X Corporation.On that date Ant contributed land with a FMV of $10,000 and an adjusted basis to A of $3,500.B contributed two capital assets: CA #1 (FMV $6,000, AB $8,000), and CA#2, FMV $6,000, AB $5,000), B also contributed a liability (which had a legitimate business purpose) of $1,000 which was assumed by X.A received 100 shares in exchange and B received 100 shares and $1,000 cash in the exchange.

DURING YEAR 1

• X received $5,000 revenue from operations
• On July 1 X distributed $1,000 cash to A and $1,000 cash to B.
• On October 15 X received $2,000 of dividends from Y corp. (X owns < 1% of Y stock)
• On December 21 X sold CA #1 for $5,000

DURING YEAR 2

• On January 1, In an unrelated transaction, X received a capital asset from W ("CAW") with a FMV of $15,000 and an adjusted basis of $12,000 to and issues 100 shares of X stock which it gave to W.
• Also on January 1 X purchased a Section 179 asset for $1,000
• On April 1 X sold CAW for $16,000capital gain1000
• On July 1 X distributed $5,000 cash to each of A, B and C ($15,000 total).
• X received $4,000 revenue from operations
• X paid $1,000 in federal tax.

DURING YEAR 3

• X receives $1,000 revenue from operations
• X distributed $333.33 to each of A, B and W

1. What is X' taxable income in Years 1, 2 and 3?

1. What income, gain or loss does A recognize in Year 1?

1. What income, gain or loss does B recognize in Year 2?

1. What is X' Accumulated E&P at the beginning of Year 3?

1. What income, gain or loss does W recognize in Year 2?

1. What income, gain or loss does W recognize in Year 3?