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Yellow Corp., an S corporation, previously operated as a C corporation. At the time the S election was made (beginning of 2019), Yellow Corp. had

Yellow Corp., an S corporation, previously operated as a C corporation. At the time the S election was made (beginning of 2019), Yellow Corp. had accumulated earnings & profits of $20,000.

At the beginning of 2020, Yellow Corp. still had accumulated E&P of $20,000 and had an AAA balance of $100,000. During 2020, Yellow Corp. reported the following:

  • Ordinary business income: $210,000
  • Separately stated income items: $10,000 (not tax-exempt income)
  • Separately stated income items: $5,000 (municipal bond interest tax-exempt)
  • Separately stated loss items: $20,000

At the beginning of 2020, Sunny, the sole shareholder of Yellow Corp., had a stock basis of $150,000. During 2020, Yellow Corp. distributed $400,000 to Sunny.

a) What amount of the distribution is treated as dividend?

b) What amount of the distribution is treated as capital gain?

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