Rowena is the sole shareholder of Rail,a calendar year C corporation.As of January 1,2012,Rail had a $300,000 deficit in accumulated E & P.For 2012,it had current E & P of $110,000 and distributed to Rowena a cash dividend of $170,000.As of January 1,2012,Rowena has a basis in her Rail stock of $40,000.

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