Question
Please consider the following, and answer the associated questions. R Inc. is an S Corporation with no E&P. It has three shareholders: J, D, and
Please consider the following, and answer the associated questions.
R Inc. is an S Corporation with no E&P. It has three shareholders: J, D, and Q. The shareholders tax basis in their R shares is as follows:
Shareholder | Number of Shares | Tax Basis |
J | 3,200 | $150,000 |
D | 4,800 | $50,000 |
Q | 8,000 | $200,000 |
In the current year, R distributed $240,000 to the shareholders.
1. Assume that the distribution was divided equally among the shareholders: $80,000 each. Would R qualify for classification as an S corporation? Explain.
2. Assume instead that the distribution was divided proportionally among the shareholders, based on the number of shares each owns: $48,000 to J, $72,000 to D, and $120,000 to Q. How much income would each shareholder recognize in connection with the distribution, and what would be its character?
3. In question 2 above, what would be each shareholders remaining basis in his or her R stock after receipt of the distribution?
4. Assume that in addition to the amount invested in R, Inc. for shares of stock, D also loaned $100,000 to the company. If the principal balance of the loan at the date of the distributions had been $62,000, how would your answer in b above change?
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