Question

Sam owns 60 percent of the stock of Club Corporation. Unrelated individuals own the remaining 40 percent. For a stock redemption of Sams stock to be treated as an exchange under the substantially disproportionate test, what percentage of Club stock must Sam own after the redemption? Multiple Choice All stock redemptions involving individuals are treated as exchanges. Any percentage less than 60 percent. Any percentage less than 48 percent. Any percentage less than 50 percent.

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Answer #1
Under §302(b)(2), Sam must own lesser of :
1) 60% of 80% =48%
2) 50%
Sam must own Any percentage less than 48 percent after the redemption
Option C is correct
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