The stock of Ebony, Inc., is owned as follows: Percent Ownership Basis FMV Alma 30 $2,700 $270,000

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The stock of Ebony, Inc., is owned as follows:

Percent Ownership Basis FMV Alma 30 $2,700 $270,000 Ben 30 2,700 270,000 Debbie 20 1,800 180,000 Clyde 20 1,800 180,000 Alma and Ben are the parents of Debbie and Clyde. Managerial positions in Ebony are as follows: Alma is the chief executive officer (CEO), Ben is the chief operating officer

(COO), Debbie is the chief financial officer (CFO), and Clyde is the vice president for human resources. Alma and Ben have owned their stock for 30 years, and Debbie and Clyde have owned their stock for 10 years. Alma and Ben are considering disposing of their stock and would like to use the funds to acquire a more lucrative investment. Their initial plan was to have Ebony redeem their stock. However, their accountant has indicated that because they intend to retain their positions as officers, the redemption will not qualify under § 302(b)(3). The accountant suggests that they sell their stock to several outsiders who want to acquire an interest in Ebony. As Debbie and Clyde expect to move into the CEO and COO positions in a few years, they oppose a sale to outsiders. They are concerned about the loss of family control that would result.

How can this family dilemma be resolved?

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South Western Federal Taxation 2013 Corporations Partnerships Estates And Trusts

ISBN: 9781133495574

36th Edition

Authors: William H. Hoffman, William A. Raabe, James E. Smith, David M. Maloney

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