Question
Petrel Corporation has accumulated E & P of $85,000 at the beginning of the year. Its current-year taxable income is $320,000. On December 31, Petrel
Petrel Corporation has accumulated E & P of $85,000 at the beginning of the year. Its current-year taxable income is $320,000. On December 31, Petrel distributed business property (land, fair market value $140,000, adjusted basis $290,000) to Juan, its sole shareholder. Juan assumes a $70,000 liability on the property.
Included in the determination of Petrel's current taxable income is $16,000 of income recognized from an installment sale in a previous year. In addition, the corporation incurred a Federal income tax liability of $67,200, it paid life insurance premiums of $4,500, and received term life insurance proceeds of $150,000 on the death of an officer.
Assume Petrel Corporation is taxed at the 21% tax rate.
What happens if Petrel instead sells the property at its fair market value, used $70,000 of the proceeds to pay off the liability, and then distributed the remaining cash and any tax savings to Juan?
If Petrel had sold the business property at its fair market value, it would have a recognized loss of ___. After paying off the loan and any taxes associated with the sale, Juan receives a dividend of ___. The E & P of Petrel Corporation after the property sale and distribution of cash to Juan is ___.
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