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, the redemption must reduce Tammy's stock ownership below 48 percent.
Tammy's stock ownership must be reduced below 50 percent and be less than 80 percent of her existing ownership (80% × 60% = 48%).
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