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X Corp. owns the following assets. X Corp. acquired the bonds by purchase after it was incorporated. Asset Tax Basis FMV Land $1,000 $3,500 Bonds

X Corp. owns the following assets. X Corp. acquired the bonds by purchase after it was incorporated.

Asset Tax Basis FMV
Land $1,000 $3,500
Bonds $4,000 $1,200
Cash $5,300 $5,300
Total $10,300 $10,000

The following shareholders own all of the stock of X Corp. as follows:

Name Tax Basis FMV Percentage of Common Stock
Christopher Smith $3,700 $5,000 50%
Mary Wilson $2,400 $3,000 30%
Jeff Erney $2,300 $2,000 20%
Total $10,000 100%

X Corp. adopts a plan of liquidation.

(a) What are the U.S. tax consequences to X Corp. and each of its shareholders if X Corp. distributes

(i) the land and $1,500 cash to Smith;

(ii) the bonds and $1,800 to Wilson; and

(iii) $2,000 to Erney?

Assume in this scenario that Smith, Wilson, and Erney are unrelated.

(b) Same facts as (a) except that Wilson is Smith's daughter. What are the U.S. tax consequences to X Corp. and each of its shareholders?

(c) What are the U.S. tax consequences to X Corp. and each of its shareholders if X Corp. distributes

(i) the land, 50% of the bonds, and $900 cash to Smith;

(ii) 30% of the bonds and $2,640 to Wilson; and

(iii) 20% of the bonds and $1,760 to Erney? Assume in this scenario that Wilson is Smith's daughter?

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