JS Corporation elected to be treated as an S corporation for federal income tax purposes. For Year 2, JS Corporation distributed Equipment A with FMV of $100 and basis of $400 to one of its 50% shareholders, Sunny at the end of year. Immediately prior to the distribution, Sunnys basis in the corporation was $300. JS Corporations income or losses for the year was $0.

1. Provide Sunnys outside basis in JS Corporation and inside basis in Equipment A immediately after the distribution.

2. Assuming that JS Corporation was a C corporation for federal income tax purposes, provide Sunnys outside basis in JS Corporation and inside basis in Equipment A immediately after the distribution. Assume that JS Corporation is subject to 21% federal income tax rate and no historical E&P was generated.

3. Assuming that JS Corporation was a partnership for federal income tax purposes, provide Sunnys outside basis in JS partnership and inside basis in Equipment A immediately after the distribution.