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Randolph is a 30 percent partner in tSam owns 60 percent of the stock of Club Corporation. Unrelated individuals own the remaining 40 percent. For
Randolph is a 30 percent partner in tSam owns 60 percent of the stock of Club Corporation. Unrelated individuals own the remaining 40 percent. For a stock redemption of Sam's stock to be treated as an exchange under the "substantially disproportionate" test, what percentage of Club stock must Sam own after the redemption? A) All stock redemptions involving individuals are treated as exchanges. B) Any percentage less than 50 percent C) Any percentage less than 60 percent D) Any percentage less than 48 percenthe RD Partnership. On January 1, RD distributes $19,000 cash and inventory with a fair value of $34,400 (inside basis of $17,200) to Randolph in complete liquidation of his interest. RD has no liabilities at the date of the distribution. Randolph's basis in his RD Partnership interest is $38,800. What is the amount and character of Randolph's gain or loss on the distribution? A) $2,600 capital loss B) $14,600 capital gain C) $14,600 capital loss D) $0 gain or loss
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