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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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