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Please treat the following case as your California clients asking for tax advice, cite the case number and subpart you are using to answer. Pellegrino

Please treat the following case as your California clients asking for tax advice, cite the case number and subpart you are using to answer.

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Pellegrino Inc. has 100 shares of common stock outstanding, which are owned as follows: Lily - 25 shares Mason -19 shares Uribe - 22 shares Connor - 18 shares Alison - 16 shares In each of the following alternative situations on each of its own merit, counsel Pellegrino as to whether the redemption qualifies as not essentially equivalent to a dividend under IRC Sec. 302(b)(1). Please show all calculations. a) Lily, Uribe and Alison are mother, father and daughter. Pellegrino redeems 24 shares from Lily. The shareholders are otherwise unrelated. b) Pellegrino redeems 10 shares from Mason, who is the son of Connor and Alison. The shareholders are otherwise unrelated. c) Pellegrino redeems 10 shares from Mason. The shareholders are otherwise unrelated. d) Pellegrino redeems 10 shares from Mason. Lily, Mason and Uribe are brothers and sisters. The shareholders are otherwise unrelated. Pellegrino Inc. has 100 shares of common stock outstanding, which are owned as follows: Lily - 25 shares Mason -19 shares Uribe - 22 shares Connor - 18 shares Alison - 16 shares In each of the following alternative situations on each of its own merit, counsel Pellegrino as to whether the redemption qualifies as not essentially equivalent to a dividend under IRC Sec. 302(b)(1). Please show all calculations. a) Lily, Uribe and Alison are mother, father and daughter. Pellegrino redeems 24 shares from Lily. The shareholders are otherwise unrelated. b) Pellegrino redeems 10 shares from Mason, who is the son of Connor and Alison. The shareholders are otherwise unrelated. c) Pellegrino redeems 10 shares from Mason. The shareholders are otherwise unrelated. d) Pellegrino redeems 10 shares from Mason. Lily, Mason and Uribe are brothers and sisters. The shareholders are otherwise unrelated

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