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Sam owns 80 percent of the stock of Club Corporation. Unrelated individuals own the remaining 20 percent. For a stock redemption of Sam's stock to

Sam owns 80 percent of the stock of Club Corporation. Unrelated individuals own the remaining 20 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?

  • Any percentage less than 64 percent.

  • Any percentage less than 50 percent.

  • Any percentage less than 80 percent.

  • All stock redemptions involving individuals are treated as exchanges.

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