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X corporation has current E&P of $ 5 , 0 0 0 , 0 0 0 and accumulated E&P of $ 2 , 0 0

X corporation has current E&P of $5,000,000 and accumulated E&P of $2,000,000. X corporation operates two lines of business a coffeeshop with assets totaling a FMV of $2,000,000 and a bike rental business with assets totaling a FMV of $2,000,000. X corporation has 100 shares outstanding of a single class of stock, namely common stock. Jack and Jill, who are unrelated, own 50 shares each. Because of an accident the coffeeshop burns down and X corporation receives insurance proceeds of $2,000,000 from its insurance company. It then distributes the proceeds to Jack and Jill $1,000,000 each in exchange for 25 shares each. Jack and Jill each have dividend income totaling $1,000,000 because there is sufficient E&P and their ownership remains 50/50 before and after the redemption.
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