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PROBLEM H and W, a married couple on the verge of divorce, each own 50 of the 100 outstanding shares of common stock (the only
PROBLEM H and W, a married couple on the verge of divorce, each own 50 of the 100 outstanding shares of common stock (the only class outstanding) of Family Corp. ("F"), which has a total value of $1 million and $500,000 of accumulated earnings and profits. H and W each have a $100,000 basis in their F stock. H and W have agreed that on the effective date of their divorce, H will own all the stock of F and W will receive $500,000 for her 50 shares. Consider the tax consequences of the following proposals to meet these goals: (a) H buys W's stock for $500,000 cash. (b) H and W agree that F will redeem W s stock for $500,000 cash. (c) How would you advise each of the parties to structure the transaction
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