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Strap Corporation is the sole shareholder of X, Inc. Strap and X do not file a consolidated return, and Strap has held its X stock

Strap Corporation is the sole shareholder of X, Inc. Strap and X do not file a consolidated return, and Strap has held its X stock for more than two years. Strap has a $150,000 basis in its X stock. Boot is a prospective buyer and is willing to purchase all of the X stock, but he is unable to pay the $500,000 price demanded by Strap even though he believes it to be fair. X has $100,000 cash on hand and an ample supply of E&P. To solve these problems the parties have agreed on the following plan. Strap Corporation will cause X to distribute $100,000 to it as a dividend. Promptly thereafter, Strap will sell its X stock to Boot for $400,000.

(a) What are the tax consequences of this plan?

(b) What if Strap were an individual rather than a corporation?

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