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TAX Inc. has 1,000 shares of stock issued and outstanding, which are owned by the following shareholders: Number of Shares Shareholder 100 A 100 A's

  1. TAX Inc. has 1,000 shares of stock issued and outstanding, which are owned by the following shareholders:

Number of Shares

Shareholder

100

A

100

A's spouse

100

A's son

100

A's sister

100

A's mother

100

A's grandfather

100

Partnership B (A is a 10% partner)

100

Partnership C (As spouse is a 60% partner)

100

Corporation D (A is a 40% shareholder)

100

Corporation E (A is an 80% shareholder)

1,000

Instructions:

Under the IRC Sec. 318 constructive ownership rules, how many shares of TAX Inc.

stock is shareholder A considered to own (directly and constructively)?

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