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X Corporation made $60,000 in distributions to its sole shareholder, Scully. X Corporation had current earnings and profits of $35,000 and accumulated earnings and profits

X Corporation made $60,000 in distributions to its sole shareholder, Scully. X Corporation had current earnings and profits of $35,000 and accumulated earnings and profits of ($50,000). What are the tax consequences of the distribution to Scully?

Which of the following would not constitute substantial authority?

A. Tax Court Case

B. Technical Advice Memorandum

C. Senate Finance Committee Report

D. Article in National Tax Journal

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