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On June 30, 2022, Corporation X made a cash distribution of $5,000 to Individual A, a 50% shareholder. On December 31, 2022, Corporation X made

On June 30, 2022, Corporation X made a cash distribution of $5,000 to Individual A, a 50% shareholder. On December 31, 2022, Corporation X made a cash distribution of $5,000 to Individual B, a 50% shareholder. X had the following earnings and profits:

A B C D = B+C E = A+D
Accumulated E&P through end of 2021 January 1 June 30, 2022 July 1 December 31, 2022 Earnings (deficit) for 2022 Through end of 2022
Earnings (deficit) (10,000) 10,000 (8,000) 2,000 (8,000)
Dividends paid 5,000 to A 5,000 to B 10,000

Assume As basis in their stock as of the beginning of 2022 was 3,000 and Bs basis in their stock as of the beginning of 2022 was 7,000.

What are the tax consequences of the distributions to each of A and B in 2022? Explain your answer, citing authority.

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