Deck 14: Corporate Nonliquidating and Liquidating Distributions

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Question
The "double taxation" of corporate income refers to the fact that corporate income is taxed at both the entity level and the shareholder level.
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Question
Diego owns 30 percent of Azul Corporation.Azul Corporation owns 50 percent of Verde Corporation.Under the attribution rules applying to stock redemptions, Diego is treated as owning 15 percent of Verde Corporation.
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Green Corporation has current earnings and profits of $100,000 and negative accumulated earnings and profits of $(200,000).A $50,000 distribution from Green to its sole shareholder will not be treated as a dividend because total earnings and profits is a negative $100,000.
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A corporation's "earnings and profits" account is equal to the company's "retained earnings" account on its balance sheet.
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Cedar Corporation incurs a net capital loss of $20,000 in year 1 that cannot be deducted on its income tax return but must be carried forward to year 2.Cedar will deduct the net capital loss in the computation of current earnings and profits for year 1.
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Only income and deductions included on a corporation's income tax return are included in the computation of current earnings and profits.
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Stock distributions are always nontaxable to the recipient.
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A distribution from a corporation to a shareholder will always be treated as a dividend for tax purposes.
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Tammy owns 60 percent of the stock of Huron Corporation.Unrelated individuals own the remaining 40 percent.For a stock redemption to be treated as an exchange under the "substantially disproportionate" rule, Tammy must reduce her stock ownership to below 48 percent.
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Evergreen Corporation distributes land with a fair market value of $50,000 to its sole shareholder.Evergreen's tax basis in the land is $200,000.Evergreen will report a loss of $150,000 on the distribution regardless of whether its earnings and profits are positive or negative.
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Terrapin Corporation incurs federal income taxes of $250,000 in year 1.Terrapin deducts the federal income taxes in computing its current earnings and profits for year 1.
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A stock redemption is always treated as a sale or exchange for tax purposes.
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The recipient of a nontaxable stock distribution will have a zero tax basis in the stock received in the distribution.
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Evergreen Corporation distributes land with a fair market value of $200,000 to its sole shareholder.Evergreen's tax basis in the land is $50,000.Assuming sufficient earnings and profits, the amount of dividend reported by the shareholder is $200,000.
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The term "earnings and profits" is well-defined in the Internal Revenue Code.
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A distribution from a corporation to a shareholder will only be treated as a dividend for tax purposes if the distribution is paid out of current and/or accumulated earnings and profits.
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Evergreen Corporation distributes land with a fair market value of $200,000 to its sole shareholder.Evergreen's tax basis in the land is $50,000.Evergreen will report a gain of $150,000 on the distribution regardless of whether its earnings and profits are positive or negative.
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Green Corporation has negative current earnings and profits of $100,000 and positive accumulated earnings and profits of $200,000.A $50,000 distribution from Green to its sole shareholder at the end of the year will be treated as a dividend because total earnings and profits is a positive $100,000.
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The recipient of a taxable stock distribution will have a tax basis in the stock equal to the fair market value of the stock received.
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Brothers and sisters are considered "family" under the stock attribution rules that apply to stock redemptions.
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Packard Corporation reported taxable income of $1,000,000 in year 3 and paid federal income taxes of $210,000.Included in the year 3 taxable income computation was a dividends received deduction of $5,000, a net capital loss carryover from year 2 of $10,000, and gain of $50,000 from an installment sale that took place in year 1.The corporation's current earnings and profits for year 3 would be:

A)$1,015,000.
B)$965,000.
C)$805,000.
D)$755,000.
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The family attribution rules are automatically waived in a complete redemption of a shareholder's stock.
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A liquidating corporation always recognizes loss realized in a complete liquidation where none of the shareholders is a corporation.
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Battle Corporation redeems 20 percent of its stock for $100,000 in a stock redemption that is treated as an exchange by the shareholders.Battle's E&P at the date of the redemption is $200,000.Battle will reduce its earnings and profits by $100,000 as a result of the redemption.
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A liquidation of a corporation always is a taxable event to the shareholders of the liquidating corporation.
Question
Which statement best describes the concept of the double taxation of corporate income?

A)Corporate income is subject to two levels of taxation: the regular tax and the alternative minimum tax.
B)Corporate income is taxed twice at the corporate level: first when earned and then a second time if appreciated property is distributed to a shareholder.
C)Corporate income is taxed when earned by a C corporation and then a second time at the shareholder level when distributed as a dividend.
D)Corporate income is subject to two levels of taxation: at the federal level and a second time at the state level.
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Au Sable Corporation reported taxable income of $800,000 in year 2 and paid federal income taxes of $168,000.Not included in the computation was a disallowed penalty of $25,000, and life insurance proceeds of $100,000.Included in the computation of taxable income is a deduction for the bargain element of exercised nonqualified stock options of $50,000.The corporation's current earnings and profits for year 2 would be:

A)$875,000.
B)$757,000.
C)$707,000.
D)$657,000.
Question
Which of the following statements best describes the role of current and accumulated earnings and profits in determining if at least a portion of a distribution is a dividend?

A)A distribution will be a dividend only to the extent total earnings and profits (current plus accumulated)is positive at the time of the distribution.
B)No part of a distribution will be a dividend if current earnings and profits is negative.
C)A distribution will be at least in part a dividend if current earnings and profits for the year is positive, even if accumulated earnings and profits is negative.
D)No part of a distribution will be a dividend if current earnings and profits for the year is negative, even if accumulated earnings and profits is positive.
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A calendar-year corporation has negative current E&P of $500 and accumulated positive E&P of $1,000.The corporation makes a $600 distribution to its sole shareholder.Which of the following statements is true?

A)$500 of the distribution will be a dividend because total earnings and profits is $500.
B)$0 of the distribution will be a dividend because current earnings and profits is negative.
C)$600 of the distribution will be a dividend because accumulated earnings and profits is $1,000.
D)Up to $600 of the distribution could be a dividend depending on the balance in accumulated earnings and profits on the date of the distribution.
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Oakland Corporation reported a net operating loss of $500,000 in year 1.Not included in the year 1 taxable income computation was a disallowed entertainment expense of $20,000, tax-exempt income of $10,000, and deferred gain on an installment sale of $250,000.The corporation's current earnings and profits for year 1 would be:

A)$(500,000).
B)$(720,000).
C)$(510,000).
D)$(260,000).
Question
Which of the following statements best describes current earnings and profits?

A)Current earnings and profits is another name for a corporation's retained earnings on its balance sheet.
B)Current earnings and profits is a precisely defined tax term in the Internal Revenue Code and represents a corporation's economic income for the year.
C)Current earnings and profits is a partially defined tax concept in the Internal Revenue Code and represents a corporation's economic income for the year.
D)Current earnings and profits is a conceptual tax concept with no definition in the Internal Revenue Code.
Question
Grand River Corporation reported taxable income of $500,000 in year 1 and paid federal income taxes of $105,000.Not included in the computation was a disallowed meals expense of $2,000, tax-exempt income of $1,000, and deferred gain on an installment sale of $25,000.The corporation's current earnings and profits for year 1 would be:

A)$524,000.
B)$500,000.
C)$419,000.
D)$395,000.
Question
Which of these items is not an adjustment to taxable income to compute current E&P?

A)Dividends received deduction.
B)Tax-exempt income.
C)Net capital loss carryforward from the prior-year tax return.
D)All of these choices are adjustments.
Question
Which of the following statements best describes the priority of the tax treatment of a distribution from a corporation to a shareholder?

A)The distribution is a dividend to the extent of the corporation's earnings and profits, then a return of capital, and finally gain from sale of stock.
B)The distribution is a return of capital, then a dividend to the extent of the corporation's earnings and profits, and finally gain from sale of stock.
C)The distribution is a return of capital, then gain from sale of stock, and finally a dividend to the extent of the corporation's earnings and profits.
D)The shareholder can elect to treat the distribution as either a dividend to the extent of the corporation's earnings and profits or a return of capital, followed by gain from sale of stock.
Question
Abbot Corporation reported a net operating loss of $400,000 in year 1.Included in the year 1 taxable income computation were regular depreciation of $100,000 (E&P depreciation is $40,000), and a dividends received deduction of $15,000.The corporation's current earnings and profits for year 1 would be:

A)$(325,000).
B)$(340,000).
C)$(400,000).
D)$(355,000).
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The tax basis of property received by a noncorporate shareholder in a complete liquidating will be the property's fair market value.
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A liquidating corporation always recognizes gain realized in a complete liquidation.
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Madison Corporation reported taxable income of $400,000 in year 2 and accrued federal income taxes of $84,000.Included in the year 2 taxable income computation were regular depreciation of $200,000 (E&P depreciation is $60,000), first-year expensing under §179 of $100,000, and a net capital loss carryover of $20,000 from year 1.The corporation's current earnings and profits for year 2 would be:

A)$556,000.
B)$536,000.
C)$640,000.
D)$476,000.
Question
A calendar-year corporation has positive current E&P of $500 and accumulated negative E&P of $1,200.The corporation makes a $400 distribution to its sole shareholder.Which of the following statements is true?

A)The distribution will not be a dividend because total earnings and profits is negative $700.
B)The distribution may be a dividend, depending on whether total earnings and profits at the date of the distribution is positive.
C)The distribution will be a dividend because current earnings and profits is positive and exceeds the distribution.
D)A distribution from a corporation to a shareholder is always a dividend, regardless of the balance in earnings and profits.
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A distribution in partial liquidation of a corporation is always treated as an exchange by an individual shareholder.
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Wildcat Corporation reports current E&P of negative $200,000 in year 1 and accumulated E&P at the beginning of the year of $100,000.Wildcat distributed $300,000 to its sole shareholder on December 31, year 1.How much of the distribution is treated as a dividend in year 1?

A)$0.
B)$100,000.
C)$200,000.
D)$300,000.
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Aztec Company reports current E&P of $200,000 in year 1 and accumulated E&P at the beginning of the year of negative $100,000.Aztec distributed $300,000 to its sole shareholder on January 1, year 1.How much of the distribution is treated as a dividend in year 1?

A)$300,000.
B)$200,000.
C)$100,000.
D)$0.
Question
Catamount Company had current and accumulated E&P of $500,000 at December 31, year 1.On December 31, the company made a distribution of land to its sole shareholder, Caroline West.The land's fair market value was $200,000 and its tax and E&P basis to Catamount was $250,000.The tax consequences of the distribution to Catamount in year 1 would be:

A)No loss recognized and a reduction in E&P of $250,000.
B)$50,000 tax and E&P loss recognized and a reduction in E&P of $250,000.
C)$50,000 tax and E&P loss recognized and a reduction in E&P of $150,000.
D)No loss recognized and a reduction in E&P of $200,000.
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Inca Company reports current E&P of negative $100,000 in year 1 and accumulated E&P at the beginning of the year of $200,000.Inca distributed $300,000 to its sole shareholder on January 1, year 1.How much of the distribution is treated as a dividend in year 1?

A)$0.
B)$100,000.
C)$200,000.
D)$300,000.
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Longhorn Company reports current E&P of $100,000 in year 1 and accumulated E&P at the beginning of the year of negative $200,000.Longhorn distributed $300,000 to its sole shareholder on January 1, year 1.The shareholder's tax basis in his Longhorn stock is $100,000.How is the distribution treated by the shareholder in year 1?

A)$300,000 dividend.
B)$100,000 dividend, $100,000 nontaxable return of basis, and $100,000 capital gain.
C)$100,000 dividend and $200,000 nontaxable return of basis.
D)$0 dividend, $100,000 nontaxable return of basis, and $200,000 capital gain.
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Paladin Corporation had current and accumulated E&P of $500,000 at December 31, year 1.On December 31, the company made a distribution of land to its sole shareholder, Maria Mendez.The land's fair market value was $200,000 and its tax and E&P basis to Paladin was $250,000.Maria assumed a liability of $25,000 attached to the land.The tax consequences of the distribution to Paladin in year 1 would be:

A)No loss recognized and a reduction in E&P of $200,000.
B)$50,000 tax and E&P loss recognized and a reduction in E&P of $200,000.
C)$50,000 tax and E&P loss recognized and a reduction in E&P of $225,000.
D)No loss recognized and a reduction in E&P of $225,000.
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Montclair Corporation had current and accumulated E&P of $500,000 at December 31, year 1.On December 31, the company made a distribution of land to its sole shareholder, Molly Pitcher.The land's fair market value was $200,000 and its tax and E&P basis to Montclair was $50,000.Molly assumed a liability of $25,000 attached to the land.The tax consequences of the distribution to Montclair in year 1 would be (assume a 0 percent marginal tax rate for Montclair):

A)No gain recognized and a reduction in E&P of $200,000.
B)$150,000 tax and E&P gain recognized and a reduction in E&P of $200,000.
C)$150,000 tax and E&P gain recognized and a reduction in E&P of $175,000.
D)No gain recognized and a reduction in E&P of $175,000.
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Tar Heel Corporation had current and accumulated E&P of $500,000 at December 31, year 1.On December 31, the company made a distribution of land to its sole shareholder, William Roy.The land's fair market value was $100,000 and its tax and E&P basis to Tar Heel was $25,000.William assumed a mortgage attached to the land of $10,000.The tax consequences of the distribution to William in year 1 would be:

A)$100,000 dividend and a tax basis in the land of $100,000.
B)$100,000 dividend and a tax basis in the land of $90,000.
C)Dividend of $90,000 and a tax basis in the land of $100,000.
D)Dividend of $90,000 and a tax basis in the land of $90,000.
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Greenwich Corporation reported a net operating loss of $800,000 in year 1.Not included in the year 1 taxable income computation were a disallowed fine of $50,000, life insurance proceeds of $500,000, and a current-year charitable contribution of $10,000 that will be carried forward to year 2.The corporation's current earnings and profits for year 1 would be:

A)$(250,000).
B)$(260,000).
C)$(300,000).
D)$(360,000).
Question
Which of the following statements is true?

A)All stock redemptions are treated as exchanges for tax purposes.
B)A stock redemption not treated as an exchange will automatically be treated as a taxable dividend.
C)All stock redemptions are treated as dividends if received by an individual.
D)A stock redemption is treated as an exchange only if it meets one of the tests specified in the Internal Revenue Code.
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Sam owns 70 percent of the stock of Club Corporation.Unrelated individuals own the remaining 30 percent.For a stock redemption of Sam's stock to be treated as an exchange under the "substantially disproportionate" test, what percentage of Club stock must Sam own after the redemption?

A)Any percentage less than 70 percent.
B)Any percentage less than 56 percent.
C)Any percentage less than 50 percent.
D)All stock redemptions involving individuals are treated as exchanges.
Question
Which of the following individuals is not considered "family" for purposes of applying the stock attribution rules to a stock redemption?

A)Parents.
B)Grandchildren.
C)Grandparents.
D)Spouse.
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Cavalier Corporation had current and accumulated E&P of $500,000 at December 31, year 1.On December 31, the company made a distribution of land to its sole shareholder, Tom Jefferson.The land's fair market value was $200,000 and its tax and E&P basis to Cavalier was $50,000.The tax consequences of the distribution to Cavalier in year 1 would be (assume a 0 percent marginal tax rate for Cavalier):

A)No gain recognized and a reduction in E&P of $200,000.
B)$150,000 tax and E&P gain recognized and a reduction in E&P of $200,000.
C)$150,000 tax and E&P gain recognized and a reduction in E&P of $50,000.
D)No gain recognized and a reduction in E&P of $50,000.
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Husker Corporation reports current E&P of negative $200,000 in year 1 and accumulated E&P at the beginning of the year of $300,000.Husker distributed $200,000 to its sole shareholder on December 31, year 1.The shareholder's tax basis in her stock in Husker is $50,000.How is the distribution treated by the shareholder in year 1?

A)$200,000 dividend.
B)$100,000 dividend, $50,000 nontaxable return of basis, and $50,000 capital gain.
C)$100,000 dividend and $100,000 nontaxable return of basis.
D)$0 dividend, $50,000 nontaxable return of basis, and $150,000 capital gain.
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Bruin Company reports current E&P of $200,000 in year 1 and accumulated E&P at the beginning of the year of $100,000.Bruin distributed $400,000 to its sole shareholder on January 1, year 1.How much of the distribution is treated as a dividend in year 1?

A)$400,000.
B)$300,000.
C)$200,000.
D)$100,000.
Question
Wonder Corporation declared a common stock distribution to all shareholders of record on September 30, year 1.Shareholders will receive three shares of Wonder stock for each five shares of stock they already own.Diana owns 300 shares of Wonder stock, with a tax basis of $90 per share (a total basis of $27,000).The fair market value of the Wonder stock was $180 per share on September 30, year 1.What are the tax consequences of the stock distribution to Diana?

A)$0 dividend income and a tax basis in the new stock of $180 per share.
B)$0 dividend income and a tax basis in the new stock of $67.50 per share.
C)$0 dividend income and a tax basis in the new stock of $56.25 per share.
D)$10,800 dividend and a tax basis in the new stock of $180 per share.
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Sara owns 80 percent of the stock of Lea Corporation.Unrelated individuals own the remaining 20 percent.For a stock redemption of Sara's stock to be treated as an exchange under the "substantially disproportionate" test, what percentage of Lea stock must Sara own after the redemption?

A)Any percentage less than 80 percent.
B)Any percentage less than 50 percent.
C)Any percentage less than 64 percent.
D)All stock redemptions involving individuals are treated as exchanges.
Question
Which of the following stock distributions would be nontaxable to the shareholder?

A)A stock distribution of one common share for every common share owned by shareholders.
B)A stock distribution where the shareholder could choose between cash and stock.
C)A stock distribution to all holders of preferred stock.
D)Both a stock distribution of one common share for every common share owned by shareholders and a stock distribution to all holders of preferred stock are nontaxable to the shareholder.
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El Toro Corporation declared a common stock distribution to all shareholders of record on June 30, year 1.Shareholders will receive one share of El Toro stock for each two shares of stock they already own.Raoul owns 300 shares of El Toro stock, with a tax basis of $60 per share.The fair market value of the El Toro stock was $100 per share on June 30, year 1.What are the tax consequences of the stock distribution to Raoul?

A)$0 dividend income and a tax basis in the new stock of $100 per share.
B)$0 dividend income and a tax basis in the new stock of $60 per share.
C)$0 dividend income and a tax basis in the new stock of $40 per share.
D)$15,000 dividend and a tax basis in the new stock of $100 per share.
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Beaver Company reports current E&P of $100,000 in year 1 and accumulated E&P at the beginning of the year of $200,000.Beaver distributed $400,000 to its sole shareholder on January 1, year 1.The shareholder's tax basis in her stock in Beaver is $200,000.How is the distribution treated by the shareholder in year 1?

A)$400,000 dividend.
B)$100,000 dividend, $200,000 nontaxable return of basis, and $100,000 capital gain.
C)$200,000 dividend and $200,000 nontaxable return of basis.
D)$300,000 dividend and $100,000 nontaxable return of basis.
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Comet Corporation is owned equally by Patrick and his sister Pam, each of whom hold 100 shares in the company.Pam wants to reduce her ownership in the company, and it was decided that the company will redeem 50 of her shares for $1,000 per share on December 31, year 1.Pam's income tax basis in each share is $500.Comet has total E&P of $250,000.What are the tax consequences to Pam as a result of the stock redemption?

A)$25,000 capital gain and a tax basis in each of her remaining shares of $500.
B)$25,000 capital gain and a tax basis in each of her remaining shares of $100.
C)$50,000 dividend and a tax basis in each of her remaining shares of $100.
D)$50,000 dividend and a tax basis in each of her remaining shares of $50.
Question
Beltway Company is owned equally by George, his brother Thomas, and a partnership owned 50 percent by George and his father, Abe.Each of the three shareholders holds 100 shares in the company.Under the §318 stock attribution rules, how many shares of Beltway stock is George deemed to own?

A)100.
B)150.
C)200.
D)300.
Question
Jalen transferred his 10 percent interest to Wolverine Company as part of a complete liquidation of the company.In the exchange he received land with a fair market value of $100,000.Jalen's basis in the Wolverine stock was $50,000.The land had a basis to Wolverine Company of $80,000.What amount of gain does Jalen recognize in the exchange and what is his basis in the land he receives?

A)$50,000 gain recognized and a basis in the land of $100,000.
B)$50,000 gain recognized and a basis in the land of $80,000.
C)No gain recognized and a basis in the land of $80,000.
D)No gain recognized and a basis in the land of $50,000.
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General Inertia Corporation made a distribution of $50,000 to Henry Tiara in partial liquidation of the company on December 31, year 1.Henry owns 500 shares (50 percent)of General Inertia.The distribution was in exchange for 250 shares of Henry's stock in the company.After the partial liquidation, Henry continued to own 50 percent of the remaining stock in General Inertia.At the time of the distribution, the shares had a fair market value of $200 per share.Henry's income tax basis in the shares was $100 per share.General Inertia had total E&P of $800,000 at the time of the distribution.What are the tax consequences to Henry as a result of the transaction?

A)Henry has dividend income of $50,000 and a tax basis in his remaining shares of $100 per share.
B)Henry has capital gain of $25,000 and a tax basis in his remaining shares of $100 per share.
C)Henry has dividend income of $50,000 and a tax basis in his remaining shares of $200 per share.
D)Henry has capital gain of $25,000 and a tax basis in his remaining shares of $200 per share.
Question
Katarina transferred her 10 percent interest to Spartan Corporation as part of a complete liquidation of the company.In the exchange she received land with a fair market value of $200,000.Katarina's basis in the Spartan stock was $100,000.The land had a basis to Spartan Company of $50,000.What amount of gain does Spartan recognize in the exchange and what is Katarina's basis in the land she receives?

A)$100,000 gain recognized by Spartan and a basis in the land of $200,000.
B)$150,000 gain recognized by Spartan and a basis in the land of $200,000.
C)No gain recognized by Spartan and a basis in the land of $100,000.
D)No gain recognized by Spartan and a basis in the land of $50,000.
Question
Billie transferred her 20 percent interest to Jean Company as part of a complete liquidation of the company.In the exchange she received land with a fair market value of $200,000.Billie's basis in the Jean stock was $100,000.The land had a basis to Jean Company of $400,000.What amount of loss does Jean recognize in the exchange and what is Billie's basis in the land she receives? Billie is not considered a related party to Jean Company.

A)$200,000 loss recognized by Jean and a basis to Billie in the land of $200,000.
B)$200,000 loss recognized by Jean and a basis to Billie in the land of $400,000.
C)No loss recognized by Jean and a basis to Billie in the land of $200,000.
D)No loss recognized by Jean and a basis to Billie in the land of $400,000.
Question
Paladin Corporation transferred its 90 percent interest to Furman Company as part of a complete liquidation of the company.In the exchange, Paladin received land with a fair market value of $1,000,000.The corporation's basis in the Furman Company stock was $400,000.The land had a basis to Furman Company of $200,000.What amount of gain does Paladin recognize in the exchange and what is its basis in the land it receives?

A)$600,000 gain recognized and a basis in the land of $1,000,000.
B)$600,000 gain recognized and a basis in the land of $400,000.
C)No gain recognized and a basis in the land of $400,000.
D)No gain recognized and a basis in the land of $200,000.
Question
Viking Corporation is owned equally by Sven and his wife, Olga, each of whom hold 100 shares in the company.Viking redeemed 75 shares of Sven's stock for $2,000 per share on December 31, year 1.Viking has total (current plus accumulated)E&P of $500,000.What are the tax consequences to Viking as a result of the stock redemption?

A)No reduction in E&P as a result of the exchange.
B)A reduction of $150,000 in E&P as a result of the exchange.
C)A reduction of $187,500 in E&P as a result of the exchange.
D)A reduction of $375,000 in E&P as a result of the exchange.
Question
Which of the following statements does not describe a tax consequence to shareholders in a complete liquidation?

A)All complete liquidations are taxable to the shareholders.
B)Complete liquidations are taxable to all individual shareholders.
C)Complete liquidations are taxable to all corporate shareholders owning stock of the liquidated corporation representing less than 80 percent or more of voting power and value.
D)Complete liquidations are tax deferred to corporate shareholders owning stock of the liquidated corporation representing 80 percent or more of voting power and value.
Question
Corona Company is owned equally by Maria, her sister Carlita, her mother, Gabriella, and her grandmother Olivia, each of whom hold 100 shares in the company.Under the family attribution rules, how many shares of Corona stock is Maria deemed to own?

A)100.
B)200.
C)300.
D)400.
Question
Red Blossom Corporation transferred its 40 percent interest to Tea Company as part of a complete liquidation of the company.In the exchange Red Blossom received land with a fair market value of $500,000.The corporation's basis in the Tea Company stock was $300,000.The land had a basis to Tea Company of $600,000.What amount of gain does Red Blossom recognize in the exchange and what is its basis in the land it receives?

A)$200,000 gain recognized and a basis in the land of $600,000.
B)$200,000 gain recognized and a basis in the land of $500,000.
C)No gain recognized and a basis in the land of $600,000.
D)No gain recognized and a basis in the land of $300,000.
Question
Which of the following statements best describes the recognition of loss on property transferred to shareholders in complete liquidation of a corporation?

A)The liquidated corporation always recognizes loss on the distribution of property in complete liquidation of the corporation.
B)The liquidated corporation never recognizes loss on the distribution of property in complete liquidation of the corporation.
C)The liquidated corporation recognizes loss on the distribution of property in complete liquidation of the corporation if the property is distributed to individuals who are not related parties to the corporation.
D)The liquidated corporation recognizes loss on the distribution of property in complete liquidation of the corporation only if the property is distributed to individuals who are related parties to the corporation.
Question
Viking Corporation is owned equally by Sven and his wife, Olga, each of whom hold 100 shares in the company.Viking redeemed 75 shares of Sven's stock in the company on December 31, year 1.Viking paid Sven $2,000 per share.His income tax basis in each share is $1,000.Viking has total E&P (current plus accumulated)of $500,000.What are the tax consequences to Sven as a result of the stock redemption?

A)$75,000 capital gain and a tax basis in each of his remaining shares of $1,000.
B)$75,000 capital gain and a tax basis in each of his remaining shares of $2,000.
C)$150,000 dividend and a tax basis in each of his remaining shares of $1,000.
D)$150,000 dividend and a tax basis in each of his remaining shares of $4,000.
Question
Panda Company is owned equally by Min, her husband, Bin, her sister Xiao, and her grandson, Han, each of whom hold 100 shares in the company.Under the family attribution rules, how many shares of Panda stock is Min deemed to own?

A)100.
B)200.
C)300.
D)400.
Question
Comet Corporation is owned equally by Patrick and his sister Pam, each of whom hold 100 shares in the company.Comet redeems 50 of Pam's shares on December 31, year 1, for $1,000 per share in a transaction that Pam treats as an exchange for tax purposes.Comet has total E&P of $160,000 on December 31, year 1.What are the tax consequences to Comet as a result of the stock redemption?

A)No reduction in E&P as a result of the exchange.
B)A reduction of $50,000 in E&P as a result of the exchange.
C)A reduction of $40,000 in E&P as a result of the exchange.
D)A reduction of $80,000 in E&P as a result of the exchange.
Question
Comet Corporation is owned equally by Patrick and his sister Pam, each of whom hold 100 shares in the company.Comet redeems 50 of Pam's shares on December 31, year 1, for $1,000 per share in a transaction that Pam treats as an exchange for tax purposes.Comet has total E&P of $250,000 on December 31, year 1.What are the tax consequences to Comet as a result of the stock redemption?

A)No reduction in E&P as a result of the exchange.
B)A reduction of $50,000 in E&P as a result of the exchange.
C)A reduction of $62,500 in E&P as a result of the exchange.
D)A reduction of $125,000 in E&P as a result of the exchange.
Question
Lansing Company is owned equally by Jennifer, her husband, Dan, and DeWitt Corporation, which is owned 50 percent by Jennifer and her sister Jane.Each of the three shareholders holds 100 shares in the company.Under the §318 stock attribution rules, how many shares of Lansing stock is DeWitt Corporation deemed to own?

A)100.
B)200.
C)250.
D)300.
Question
General Inertia Corporation made a pro rata distribution of $50,000 to Tiara, Inc., in partial liquidation of the company on December 31, year 1.Tiara, Inc., owns 500 shares (50 percent)of General Inertia.The distribution was in exchange for 250 shares of Tiara's stock in the company.After the partial liquidation, Tiara continued to own 50 percent of the remaining stock in General Inertia.At the time of the distribution, the shares had a fair market value of $200 per share.Tiara's income tax basis in the shares was $100 per share.General Inertia had total E&P of $800,000 at the time of the distribution.What amount of dividend or capital gain does Tiara recognize as a result of the transaction?

A)Tiara does not recognize any dividend income or capital gain.
B)Tiara recognizes capital gain of $50,000.
C)Tiara recognizes dividend income of $50,000.
D)Tiara recognizes capital gain of $25,000.
Question
Tammy owns 100 shares in Star Struck Corporation.The other 100 shares are owned by her husband, Tommy.Which of the following statements is true?

A)A stock redemption that completely terminates Tammy's direct interest in a corporation will be treated as an exchange for tax purposes under any circumstance.
B)A stock redemption that completely terminates Tammy's direct interest in a corporation will be treated as a dividend for tax purposes if Tammy waives the family attribution rules and files a "triple i" agreement with the IRS.
C)A stock redemption that completely terminates Tammy's direct interest in a corporation will be treated as an exchange if Tammy waives the family attribution rules and files a "triple i" agreement with the IRS.
D)None of these choices are true.
Question
Lansing Company is owned equally by Jennifer, her husband, Dan, and DeWitt Corporation, which is owned 50 percent by Jennifer and her sister Jane.Each of the three shareholders holds 100 shares in the company.Under the §318 stock attribution rules, how many shares of Lansing stock is Jennifer deemed to own?

A)100.
B)200.
C)250.
D)300.
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Deck 14: Corporate Nonliquidating and Liquidating Distributions
1
The "double taxation" of corporate income refers to the fact that corporate income is taxed at both the entity level and the shareholder level.
True
2
Diego owns 30 percent of Azul Corporation.Azul Corporation owns 50 percent of Verde Corporation.Under the attribution rules applying to stock redemptions, Diego is treated as owning 15 percent of Verde Corporation.
False
3
Green Corporation has current earnings and profits of $100,000 and negative accumulated earnings and profits of $(200,000).A $50,000 distribution from Green to its sole shareholder will not be treated as a dividend because total earnings and profits is a negative $100,000.
False
4
A corporation's "earnings and profits" account is equal to the company's "retained earnings" account on its balance sheet.
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5
Cedar Corporation incurs a net capital loss of $20,000 in year 1 that cannot be deducted on its income tax return but must be carried forward to year 2.Cedar will deduct the net capital loss in the computation of current earnings and profits for year 1.
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6
Only income and deductions included on a corporation's income tax return are included in the computation of current earnings and profits.
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7
Stock distributions are always nontaxable to the recipient.
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8
A distribution from a corporation to a shareholder will always be treated as a dividend for tax purposes.
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9
Tammy owns 60 percent of the stock of Huron Corporation.Unrelated individuals own the remaining 40 percent.For a stock redemption to be treated as an exchange under the "substantially disproportionate" rule, Tammy must reduce her stock ownership to below 48 percent.
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10
Evergreen Corporation distributes land with a fair market value of $50,000 to its sole shareholder.Evergreen's tax basis in the land is $200,000.Evergreen will report a loss of $150,000 on the distribution regardless of whether its earnings and profits are positive or negative.
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11
Terrapin Corporation incurs federal income taxes of $250,000 in year 1.Terrapin deducts the federal income taxes in computing its current earnings and profits for year 1.
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12
A stock redemption is always treated as a sale or exchange for tax purposes.
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13
The recipient of a nontaxable stock distribution will have a zero tax basis in the stock received in the distribution.
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14
Evergreen Corporation distributes land with a fair market value of $200,000 to its sole shareholder.Evergreen's tax basis in the land is $50,000.Assuming sufficient earnings and profits, the amount of dividend reported by the shareholder is $200,000.
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15
The term "earnings and profits" is well-defined in the Internal Revenue Code.
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16
A distribution from a corporation to a shareholder will only be treated as a dividend for tax purposes if the distribution is paid out of current and/or accumulated earnings and profits.
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17
Evergreen Corporation distributes land with a fair market value of $200,000 to its sole shareholder.Evergreen's tax basis in the land is $50,000.Evergreen will report a gain of $150,000 on the distribution regardless of whether its earnings and profits are positive or negative.
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18
Green Corporation has negative current earnings and profits of $100,000 and positive accumulated earnings and profits of $200,000.A $50,000 distribution from Green to its sole shareholder at the end of the year will be treated as a dividend because total earnings and profits is a positive $100,000.
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19
The recipient of a taxable stock distribution will have a tax basis in the stock equal to the fair market value of the stock received.
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20
Brothers and sisters are considered "family" under the stock attribution rules that apply to stock redemptions.
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21
Packard Corporation reported taxable income of $1,000,000 in year 3 and paid federal income taxes of $210,000.Included in the year 3 taxable income computation was a dividends received deduction of $5,000, a net capital loss carryover from year 2 of $10,000, and gain of $50,000 from an installment sale that took place in year 1.The corporation's current earnings and profits for year 3 would be:

A)$1,015,000.
B)$965,000.
C)$805,000.
D)$755,000.
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22
The family attribution rules are automatically waived in a complete redemption of a shareholder's stock.
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23
A liquidating corporation always recognizes loss realized in a complete liquidation where none of the shareholders is a corporation.
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24
Battle Corporation redeems 20 percent of its stock for $100,000 in a stock redemption that is treated as an exchange by the shareholders.Battle's E&P at the date of the redemption is $200,000.Battle will reduce its earnings and profits by $100,000 as a result of the redemption.
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25
A liquidation of a corporation always is a taxable event to the shareholders of the liquidating corporation.
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26
Which statement best describes the concept of the double taxation of corporate income?

A)Corporate income is subject to two levels of taxation: the regular tax and the alternative minimum tax.
B)Corporate income is taxed twice at the corporate level: first when earned and then a second time if appreciated property is distributed to a shareholder.
C)Corporate income is taxed when earned by a C corporation and then a second time at the shareholder level when distributed as a dividend.
D)Corporate income is subject to two levels of taxation: at the federal level and a second time at the state level.
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27
Au Sable Corporation reported taxable income of $800,000 in year 2 and paid federal income taxes of $168,000.Not included in the computation was a disallowed penalty of $25,000, and life insurance proceeds of $100,000.Included in the computation of taxable income is a deduction for the bargain element of exercised nonqualified stock options of $50,000.The corporation's current earnings and profits for year 2 would be:

A)$875,000.
B)$757,000.
C)$707,000.
D)$657,000.
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28
Which of the following statements best describes the role of current and accumulated earnings and profits in determining if at least a portion of a distribution is a dividend?

A)A distribution will be a dividend only to the extent total earnings and profits (current plus accumulated)is positive at the time of the distribution.
B)No part of a distribution will be a dividend if current earnings and profits is negative.
C)A distribution will be at least in part a dividend if current earnings and profits for the year is positive, even if accumulated earnings and profits is negative.
D)No part of a distribution will be a dividend if current earnings and profits for the year is negative, even if accumulated earnings and profits is positive.
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29
A calendar-year corporation has negative current E&P of $500 and accumulated positive E&P of $1,000.The corporation makes a $600 distribution to its sole shareholder.Which of the following statements is true?

A)$500 of the distribution will be a dividend because total earnings and profits is $500.
B)$0 of the distribution will be a dividend because current earnings and profits is negative.
C)$600 of the distribution will be a dividend because accumulated earnings and profits is $1,000.
D)Up to $600 of the distribution could be a dividend depending on the balance in accumulated earnings and profits on the date of the distribution.
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30
Oakland Corporation reported a net operating loss of $500,000 in year 1.Not included in the year 1 taxable income computation was a disallowed entertainment expense of $20,000, tax-exempt income of $10,000, and deferred gain on an installment sale of $250,000.The corporation's current earnings and profits for year 1 would be:

A)$(500,000).
B)$(720,000).
C)$(510,000).
D)$(260,000).
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31
Which of the following statements best describes current earnings and profits?

A)Current earnings and profits is another name for a corporation's retained earnings on its balance sheet.
B)Current earnings and profits is a precisely defined tax term in the Internal Revenue Code and represents a corporation's economic income for the year.
C)Current earnings and profits is a partially defined tax concept in the Internal Revenue Code and represents a corporation's economic income for the year.
D)Current earnings and profits is a conceptual tax concept with no definition in the Internal Revenue Code.
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32
Grand River Corporation reported taxable income of $500,000 in year 1 and paid federal income taxes of $105,000.Not included in the computation was a disallowed meals expense of $2,000, tax-exempt income of $1,000, and deferred gain on an installment sale of $25,000.The corporation's current earnings and profits for year 1 would be:

A)$524,000.
B)$500,000.
C)$419,000.
D)$395,000.
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33
Which of these items is not an adjustment to taxable income to compute current E&P?

A)Dividends received deduction.
B)Tax-exempt income.
C)Net capital loss carryforward from the prior-year tax return.
D)All of these choices are adjustments.
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34
Which of the following statements best describes the priority of the tax treatment of a distribution from a corporation to a shareholder?

A)The distribution is a dividend to the extent of the corporation's earnings and profits, then a return of capital, and finally gain from sale of stock.
B)The distribution is a return of capital, then a dividend to the extent of the corporation's earnings and profits, and finally gain from sale of stock.
C)The distribution is a return of capital, then gain from sale of stock, and finally a dividend to the extent of the corporation's earnings and profits.
D)The shareholder can elect to treat the distribution as either a dividend to the extent of the corporation's earnings and profits or a return of capital, followed by gain from sale of stock.
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35
Abbot Corporation reported a net operating loss of $400,000 in year 1.Included in the year 1 taxable income computation were regular depreciation of $100,000 (E&P depreciation is $40,000), and a dividends received deduction of $15,000.The corporation's current earnings and profits for year 1 would be:

A)$(325,000).
B)$(340,000).
C)$(400,000).
D)$(355,000).
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36
The tax basis of property received by a noncorporate shareholder in a complete liquidating will be the property's fair market value.
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37
A liquidating corporation always recognizes gain realized in a complete liquidation.
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38
Madison Corporation reported taxable income of $400,000 in year 2 and accrued federal income taxes of $84,000.Included in the year 2 taxable income computation were regular depreciation of $200,000 (E&P depreciation is $60,000), first-year expensing under §179 of $100,000, and a net capital loss carryover of $20,000 from year 1.The corporation's current earnings and profits for year 2 would be:

A)$556,000.
B)$536,000.
C)$640,000.
D)$476,000.
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39
A calendar-year corporation has positive current E&P of $500 and accumulated negative E&P of $1,200.The corporation makes a $400 distribution to its sole shareholder.Which of the following statements is true?

A)The distribution will not be a dividend because total earnings and profits is negative $700.
B)The distribution may be a dividend, depending on whether total earnings and profits at the date of the distribution is positive.
C)The distribution will be a dividend because current earnings and profits is positive and exceeds the distribution.
D)A distribution from a corporation to a shareholder is always a dividend, regardless of the balance in earnings and profits.
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40
A distribution in partial liquidation of a corporation is always treated as an exchange by an individual shareholder.
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41
Wildcat Corporation reports current E&P of negative $200,000 in year 1 and accumulated E&P at the beginning of the year of $100,000.Wildcat distributed $300,000 to its sole shareholder on December 31, year 1.How much of the distribution is treated as a dividend in year 1?

A)$0.
B)$100,000.
C)$200,000.
D)$300,000.
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42
Aztec Company reports current E&P of $200,000 in year 1 and accumulated E&P at the beginning of the year of negative $100,000.Aztec distributed $300,000 to its sole shareholder on January 1, year 1.How much of the distribution is treated as a dividend in year 1?

A)$300,000.
B)$200,000.
C)$100,000.
D)$0.
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43
Catamount Company had current and accumulated E&P of $500,000 at December 31, year 1.On December 31, the company made a distribution of land to its sole shareholder, Caroline West.The land's fair market value was $200,000 and its tax and E&P basis to Catamount was $250,000.The tax consequences of the distribution to Catamount in year 1 would be:

A)No loss recognized and a reduction in E&P of $250,000.
B)$50,000 tax and E&P loss recognized and a reduction in E&P of $250,000.
C)$50,000 tax and E&P loss recognized and a reduction in E&P of $150,000.
D)No loss recognized and a reduction in E&P of $200,000.
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44
Inca Company reports current E&P of negative $100,000 in year 1 and accumulated E&P at the beginning of the year of $200,000.Inca distributed $300,000 to its sole shareholder on January 1, year 1.How much of the distribution is treated as a dividend in year 1?

A)$0.
B)$100,000.
C)$200,000.
D)$300,000.
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45
Longhorn Company reports current E&P of $100,000 in year 1 and accumulated E&P at the beginning of the year of negative $200,000.Longhorn distributed $300,000 to its sole shareholder on January 1, year 1.The shareholder's tax basis in his Longhorn stock is $100,000.How is the distribution treated by the shareholder in year 1?

A)$300,000 dividend.
B)$100,000 dividend, $100,000 nontaxable return of basis, and $100,000 capital gain.
C)$100,000 dividend and $200,000 nontaxable return of basis.
D)$0 dividend, $100,000 nontaxable return of basis, and $200,000 capital gain.
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46
Paladin Corporation had current and accumulated E&P of $500,000 at December 31, year 1.On December 31, the company made a distribution of land to its sole shareholder, Maria Mendez.The land's fair market value was $200,000 and its tax and E&P basis to Paladin was $250,000.Maria assumed a liability of $25,000 attached to the land.The tax consequences of the distribution to Paladin in year 1 would be:

A)No loss recognized and a reduction in E&P of $200,000.
B)$50,000 tax and E&P loss recognized and a reduction in E&P of $200,000.
C)$50,000 tax and E&P loss recognized and a reduction in E&P of $225,000.
D)No loss recognized and a reduction in E&P of $225,000.
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47
Montclair Corporation had current and accumulated E&P of $500,000 at December 31, year 1.On December 31, the company made a distribution of land to its sole shareholder, Molly Pitcher.The land's fair market value was $200,000 and its tax and E&P basis to Montclair was $50,000.Molly assumed a liability of $25,000 attached to the land.The tax consequences of the distribution to Montclair in year 1 would be (assume a 0 percent marginal tax rate for Montclair):

A)No gain recognized and a reduction in E&P of $200,000.
B)$150,000 tax and E&P gain recognized and a reduction in E&P of $200,000.
C)$150,000 tax and E&P gain recognized and a reduction in E&P of $175,000.
D)No gain recognized and a reduction in E&P of $175,000.
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48
Tar Heel Corporation had current and accumulated E&P of $500,000 at December 31, year 1.On December 31, the company made a distribution of land to its sole shareholder, William Roy.The land's fair market value was $100,000 and its tax and E&P basis to Tar Heel was $25,000.William assumed a mortgage attached to the land of $10,000.The tax consequences of the distribution to William in year 1 would be:

A)$100,000 dividend and a tax basis in the land of $100,000.
B)$100,000 dividend and a tax basis in the land of $90,000.
C)Dividend of $90,000 and a tax basis in the land of $100,000.
D)Dividend of $90,000 and a tax basis in the land of $90,000.
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49
Greenwich Corporation reported a net operating loss of $800,000 in year 1.Not included in the year 1 taxable income computation were a disallowed fine of $50,000, life insurance proceeds of $500,000, and a current-year charitable contribution of $10,000 that will be carried forward to year 2.The corporation's current earnings and profits for year 1 would be:

A)$(250,000).
B)$(260,000).
C)$(300,000).
D)$(360,000).
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50
Which of the following statements is true?

A)All stock redemptions are treated as exchanges for tax purposes.
B)A stock redemption not treated as an exchange will automatically be treated as a taxable dividend.
C)All stock redemptions are treated as dividends if received by an individual.
D)A stock redemption is treated as an exchange only if it meets one of the tests specified in the Internal Revenue Code.
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51
Sam owns 70 percent of the stock of Club Corporation.Unrelated individuals own the remaining 30 percent.For a stock redemption of Sam's stock to be treated as an exchange under the "substantially disproportionate" test, what percentage of Club stock must Sam own after the redemption?

A)Any percentage less than 70 percent.
B)Any percentage less than 56 percent.
C)Any percentage less than 50 percent.
D)All stock redemptions involving individuals are treated as exchanges.
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52
Which of the following individuals is not considered "family" for purposes of applying the stock attribution rules to a stock redemption?

A)Parents.
B)Grandchildren.
C)Grandparents.
D)Spouse.
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53
Cavalier Corporation had current and accumulated E&P of $500,000 at December 31, year 1.On December 31, the company made a distribution of land to its sole shareholder, Tom Jefferson.The land's fair market value was $200,000 and its tax and E&P basis to Cavalier was $50,000.The tax consequences of the distribution to Cavalier in year 1 would be (assume a 0 percent marginal tax rate for Cavalier):

A)No gain recognized and a reduction in E&P of $200,000.
B)$150,000 tax and E&P gain recognized and a reduction in E&P of $200,000.
C)$150,000 tax and E&P gain recognized and a reduction in E&P of $50,000.
D)No gain recognized and a reduction in E&P of $50,000.
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54
Husker Corporation reports current E&P of negative $200,000 in year 1 and accumulated E&P at the beginning of the year of $300,000.Husker distributed $200,000 to its sole shareholder on December 31, year 1.The shareholder's tax basis in her stock in Husker is $50,000.How is the distribution treated by the shareholder in year 1?

A)$200,000 dividend.
B)$100,000 dividend, $50,000 nontaxable return of basis, and $50,000 capital gain.
C)$100,000 dividend and $100,000 nontaxable return of basis.
D)$0 dividend, $50,000 nontaxable return of basis, and $150,000 capital gain.
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55
Bruin Company reports current E&P of $200,000 in year 1 and accumulated E&P at the beginning of the year of $100,000.Bruin distributed $400,000 to its sole shareholder on January 1, year 1.How much of the distribution is treated as a dividend in year 1?

A)$400,000.
B)$300,000.
C)$200,000.
D)$100,000.
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56
Wonder Corporation declared a common stock distribution to all shareholders of record on September 30, year 1.Shareholders will receive three shares of Wonder stock for each five shares of stock they already own.Diana owns 300 shares of Wonder stock, with a tax basis of $90 per share (a total basis of $27,000).The fair market value of the Wonder stock was $180 per share on September 30, year 1.What are the tax consequences of the stock distribution to Diana?

A)$0 dividend income and a tax basis in the new stock of $180 per share.
B)$0 dividend income and a tax basis in the new stock of $67.50 per share.
C)$0 dividend income and a tax basis in the new stock of $56.25 per share.
D)$10,800 dividend and a tax basis in the new stock of $180 per share.
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57
Sara owns 80 percent of the stock of Lea Corporation.Unrelated individuals own the remaining 20 percent.For a stock redemption of Sara's stock to be treated as an exchange under the "substantially disproportionate" test, what percentage of Lea stock must Sara own after the redemption?

A)Any percentage less than 80 percent.
B)Any percentage less than 50 percent.
C)Any percentage less than 64 percent.
D)All stock redemptions involving individuals are treated as exchanges.
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58
Which of the following stock distributions would be nontaxable to the shareholder?

A)A stock distribution of one common share for every common share owned by shareholders.
B)A stock distribution where the shareholder could choose between cash and stock.
C)A stock distribution to all holders of preferred stock.
D)Both a stock distribution of one common share for every common share owned by shareholders and a stock distribution to all holders of preferred stock are nontaxable to the shareholder.
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59
El Toro Corporation declared a common stock distribution to all shareholders of record on June 30, year 1.Shareholders will receive one share of El Toro stock for each two shares of stock they already own.Raoul owns 300 shares of El Toro stock, with a tax basis of $60 per share.The fair market value of the El Toro stock was $100 per share on June 30, year 1.What are the tax consequences of the stock distribution to Raoul?

A)$0 dividend income and a tax basis in the new stock of $100 per share.
B)$0 dividend income and a tax basis in the new stock of $60 per share.
C)$0 dividend income and a tax basis in the new stock of $40 per share.
D)$15,000 dividend and a tax basis in the new stock of $100 per share.
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60
Beaver Company reports current E&P of $100,000 in year 1 and accumulated E&P at the beginning of the year of $200,000.Beaver distributed $400,000 to its sole shareholder on January 1, year 1.The shareholder's tax basis in her stock in Beaver is $200,000.How is the distribution treated by the shareholder in year 1?

A)$400,000 dividend.
B)$100,000 dividend, $200,000 nontaxable return of basis, and $100,000 capital gain.
C)$200,000 dividend and $200,000 nontaxable return of basis.
D)$300,000 dividend and $100,000 nontaxable return of basis.
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61
Comet Corporation is owned equally by Patrick and his sister Pam, each of whom hold 100 shares in the company.Pam wants to reduce her ownership in the company, and it was decided that the company will redeem 50 of her shares for $1,000 per share on December 31, year 1.Pam's income tax basis in each share is $500.Comet has total E&P of $250,000.What are the tax consequences to Pam as a result of the stock redemption?

A)$25,000 capital gain and a tax basis in each of her remaining shares of $500.
B)$25,000 capital gain and a tax basis in each of her remaining shares of $100.
C)$50,000 dividend and a tax basis in each of her remaining shares of $100.
D)$50,000 dividend and a tax basis in each of her remaining shares of $50.
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62
Beltway Company is owned equally by George, his brother Thomas, and a partnership owned 50 percent by George and his father, Abe.Each of the three shareholders holds 100 shares in the company.Under the §318 stock attribution rules, how many shares of Beltway stock is George deemed to own?

A)100.
B)150.
C)200.
D)300.
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63
Jalen transferred his 10 percent interest to Wolverine Company as part of a complete liquidation of the company.In the exchange he received land with a fair market value of $100,000.Jalen's basis in the Wolverine stock was $50,000.The land had a basis to Wolverine Company of $80,000.What amount of gain does Jalen recognize in the exchange and what is his basis in the land he receives?

A)$50,000 gain recognized and a basis in the land of $100,000.
B)$50,000 gain recognized and a basis in the land of $80,000.
C)No gain recognized and a basis in the land of $80,000.
D)No gain recognized and a basis in the land of $50,000.
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64
General Inertia Corporation made a distribution of $50,000 to Henry Tiara in partial liquidation of the company on December 31, year 1.Henry owns 500 shares (50 percent)of General Inertia.The distribution was in exchange for 250 shares of Henry's stock in the company.After the partial liquidation, Henry continued to own 50 percent of the remaining stock in General Inertia.At the time of the distribution, the shares had a fair market value of $200 per share.Henry's income tax basis in the shares was $100 per share.General Inertia had total E&P of $800,000 at the time of the distribution.What are the tax consequences to Henry as a result of the transaction?

A)Henry has dividend income of $50,000 and a tax basis in his remaining shares of $100 per share.
B)Henry has capital gain of $25,000 and a tax basis in his remaining shares of $100 per share.
C)Henry has dividend income of $50,000 and a tax basis in his remaining shares of $200 per share.
D)Henry has capital gain of $25,000 and a tax basis in his remaining shares of $200 per share.
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65
Katarina transferred her 10 percent interest to Spartan Corporation as part of a complete liquidation of the company.In the exchange she received land with a fair market value of $200,000.Katarina's basis in the Spartan stock was $100,000.The land had a basis to Spartan Company of $50,000.What amount of gain does Spartan recognize in the exchange and what is Katarina's basis in the land she receives?

A)$100,000 gain recognized by Spartan and a basis in the land of $200,000.
B)$150,000 gain recognized by Spartan and a basis in the land of $200,000.
C)No gain recognized by Spartan and a basis in the land of $100,000.
D)No gain recognized by Spartan and a basis in the land of $50,000.
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66
Billie transferred her 20 percent interest to Jean Company as part of a complete liquidation of the company.In the exchange she received land with a fair market value of $200,000.Billie's basis in the Jean stock was $100,000.The land had a basis to Jean Company of $400,000.What amount of loss does Jean recognize in the exchange and what is Billie's basis in the land she receives? Billie is not considered a related party to Jean Company.

A)$200,000 loss recognized by Jean and a basis to Billie in the land of $200,000.
B)$200,000 loss recognized by Jean and a basis to Billie in the land of $400,000.
C)No loss recognized by Jean and a basis to Billie in the land of $200,000.
D)No loss recognized by Jean and a basis to Billie in the land of $400,000.
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67
Paladin Corporation transferred its 90 percent interest to Furman Company as part of a complete liquidation of the company.In the exchange, Paladin received land with a fair market value of $1,000,000.The corporation's basis in the Furman Company stock was $400,000.The land had a basis to Furman Company of $200,000.What amount of gain does Paladin recognize in the exchange and what is its basis in the land it receives?

A)$600,000 gain recognized and a basis in the land of $1,000,000.
B)$600,000 gain recognized and a basis in the land of $400,000.
C)No gain recognized and a basis in the land of $400,000.
D)No gain recognized and a basis in the land of $200,000.
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68
Viking Corporation is owned equally by Sven and his wife, Olga, each of whom hold 100 shares in the company.Viking redeemed 75 shares of Sven's stock for $2,000 per share on December 31, year 1.Viking has total (current plus accumulated)E&P of $500,000.What are the tax consequences to Viking as a result of the stock redemption?

A)No reduction in E&P as a result of the exchange.
B)A reduction of $150,000 in E&P as a result of the exchange.
C)A reduction of $187,500 in E&P as a result of the exchange.
D)A reduction of $375,000 in E&P as a result of the exchange.
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69
Which of the following statements does not describe a tax consequence to shareholders in a complete liquidation?

A)All complete liquidations are taxable to the shareholders.
B)Complete liquidations are taxable to all individual shareholders.
C)Complete liquidations are taxable to all corporate shareholders owning stock of the liquidated corporation representing less than 80 percent or more of voting power and value.
D)Complete liquidations are tax deferred to corporate shareholders owning stock of the liquidated corporation representing 80 percent or more of voting power and value.
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70
Corona Company is owned equally by Maria, her sister Carlita, her mother, Gabriella, and her grandmother Olivia, each of whom hold 100 shares in the company.Under the family attribution rules, how many shares of Corona stock is Maria deemed to own?

A)100.
B)200.
C)300.
D)400.
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71
Red Blossom Corporation transferred its 40 percent interest to Tea Company as part of a complete liquidation of the company.In the exchange Red Blossom received land with a fair market value of $500,000.The corporation's basis in the Tea Company stock was $300,000.The land had a basis to Tea Company of $600,000.What amount of gain does Red Blossom recognize in the exchange and what is its basis in the land it receives?

A)$200,000 gain recognized and a basis in the land of $600,000.
B)$200,000 gain recognized and a basis in the land of $500,000.
C)No gain recognized and a basis in the land of $600,000.
D)No gain recognized and a basis in the land of $300,000.
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72
Which of the following statements best describes the recognition of loss on property transferred to shareholders in complete liquidation of a corporation?

A)The liquidated corporation always recognizes loss on the distribution of property in complete liquidation of the corporation.
B)The liquidated corporation never recognizes loss on the distribution of property in complete liquidation of the corporation.
C)The liquidated corporation recognizes loss on the distribution of property in complete liquidation of the corporation if the property is distributed to individuals who are not related parties to the corporation.
D)The liquidated corporation recognizes loss on the distribution of property in complete liquidation of the corporation only if the property is distributed to individuals who are related parties to the corporation.
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73
Viking Corporation is owned equally by Sven and his wife, Olga, each of whom hold 100 shares in the company.Viking redeemed 75 shares of Sven's stock in the company on December 31, year 1.Viking paid Sven $2,000 per share.His income tax basis in each share is $1,000.Viking has total E&P (current plus accumulated)of $500,000.What are the tax consequences to Sven as a result of the stock redemption?

A)$75,000 capital gain and a tax basis in each of his remaining shares of $1,000.
B)$75,000 capital gain and a tax basis in each of his remaining shares of $2,000.
C)$150,000 dividend and a tax basis in each of his remaining shares of $1,000.
D)$150,000 dividend and a tax basis in each of his remaining shares of $4,000.
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74
Panda Company is owned equally by Min, her husband, Bin, her sister Xiao, and her grandson, Han, each of whom hold 100 shares in the company.Under the family attribution rules, how many shares of Panda stock is Min deemed to own?

A)100.
B)200.
C)300.
D)400.
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75
Comet Corporation is owned equally by Patrick and his sister Pam, each of whom hold 100 shares in the company.Comet redeems 50 of Pam's shares on December 31, year 1, for $1,000 per share in a transaction that Pam treats as an exchange for tax purposes.Comet has total E&P of $160,000 on December 31, year 1.What are the tax consequences to Comet as a result of the stock redemption?

A)No reduction in E&P as a result of the exchange.
B)A reduction of $50,000 in E&P as a result of the exchange.
C)A reduction of $40,000 in E&P as a result of the exchange.
D)A reduction of $80,000 in E&P as a result of the exchange.
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76
Comet Corporation is owned equally by Patrick and his sister Pam, each of whom hold 100 shares in the company.Comet redeems 50 of Pam's shares on December 31, year 1, for $1,000 per share in a transaction that Pam treats as an exchange for tax purposes.Comet has total E&P of $250,000 on December 31, year 1.What are the tax consequences to Comet as a result of the stock redemption?

A)No reduction in E&P as a result of the exchange.
B)A reduction of $50,000 in E&P as a result of the exchange.
C)A reduction of $62,500 in E&P as a result of the exchange.
D)A reduction of $125,000 in E&P as a result of the exchange.
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77
Lansing Company is owned equally by Jennifer, her husband, Dan, and DeWitt Corporation, which is owned 50 percent by Jennifer and her sister Jane.Each of the three shareholders holds 100 shares in the company.Under the §318 stock attribution rules, how many shares of Lansing stock is DeWitt Corporation deemed to own?

A)100.
B)200.
C)250.
D)300.
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78
General Inertia Corporation made a pro rata distribution of $50,000 to Tiara, Inc., in partial liquidation of the company on December 31, year 1.Tiara, Inc., owns 500 shares (50 percent)of General Inertia.The distribution was in exchange for 250 shares of Tiara's stock in the company.After the partial liquidation, Tiara continued to own 50 percent of the remaining stock in General Inertia.At the time of the distribution, the shares had a fair market value of $200 per share.Tiara's income tax basis in the shares was $100 per share.General Inertia had total E&P of $800,000 at the time of the distribution.What amount of dividend or capital gain does Tiara recognize as a result of the transaction?

A)Tiara does not recognize any dividend income or capital gain.
B)Tiara recognizes capital gain of $50,000.
C)Tiara recognizes dividend income of $50,000.
D)Tiara recognizes capital gain of $25,000.
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79
Tammy owns 100 shares in Star Struck Corporation.The other 100 shares are owned by her husband, Tommy.Which of the following statements is true?

A)A stock redemption that completely terminates Tammy's direct interest in a corporation will be treated as an exchange for tax purposes under any circumstance.
B)A stock redemption that completely terminates Tammy's direct interest in a corporation will be treated as a dividend for tax purposes if Tammy waives the family attribution rules and files a "triple i" agreement with the IRS.
C)A stock redemption that completely terminates Tammy's direct interest in a corporation will be treated as an exchange if Tammy waives the family attribution rules and files a "triple i" agreement with the IRS.
D)None of these choices are true.
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80
Lansing Company is owned equally by Jennifer, her husband, Dan, and DeWitt Corporation, which is owned 50 percent by Jennifer and her sister Jane.Each of the three shareholders holds 100 shares in the company.Under the §318 stock attribution rules, how many shares of Lansing stock is Jennifer deemed to own?

A)100.
B)200.
C)250.
D)300.
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