Question

Problem

1. Wham Corp. has 100 Shares of common stock outstanding. 25 shares are owned by grandfather, 20 shares are owned by Mother (grandfthers daughter), 15 shares are owned by Mother's

207 110 REDEMPTIONS AND PARTIAL LIQUIDATIONS CHAPTER 5 Daughter, 10 shares are owned by Mother's adopted Son, and the remaining 30 shares are owned by Grandmother's estate, of which Mother is a 50% beneficiary. One of Mother's cousins is the other beneficiary of the estate. Mother also has an option to purchase 5 of Son's shares. How much Wham stock do Grandfather, Mother's Daughter and Grandmother's estate own after application of $ 318? 2. All the 100 shares of Xerxes Corporation are owned by Partnership, in which A, B, C and D (all unrelated to each other) are equal partners. W, A's wife, owns all of the 100 shares of Yancy Corporation. (a) How many shares, if any, of Xerxes Corporation are owned by A, W and M (W's mother)? (b) How many shares, if any, of Xerxes are owned by Yancy? Would Yancy constructively own any shares of Xerxes if W owned only 10 percent of Yancy? (c) How many shares, if any, of Yancy are owned by Partnership, B, C, D and Xerxes? RIDAD TODD Απ πττο.

Answer 1

2.

A , B , C and D ( Unrelated )	W(A's Wife)	M ,(W's Mother )
Equall Patner in Partnership and Hold 100% Share Xerxes Corporation	100% Share of Yancy Corporation
25% shares by each Partner

a) Numbers of Share of Xerxes own by

A	25 Share	As per Code §318(a)(2)(A) Partnership or Estate to the Partner on Proportion basis
W (A's Wife )	25 Share own by A	As per Code §318(a)(1)(A) Family Deemed Ownership attribution to Spouse , Childeren , Grandchildren , and Parents
M (W' Mother )	Nothing	W's Mother does not own any share Xerxes , Share attributed to W from A does not reattributed to M under family attribution Rules .§318(a)(5)(B)

b) Under Code §318(a)(3) Shares owned by 50% or more Shareholder is Attributed to Corporation .

Yancy holds 25 Shares owned by W , first Partnership to A and A's Wise is W , W holds 50% or more in Yancy , Hence Yancy holds 25 Shares in Xerxes.

c) Shares of Yancy holds by Partner

Partnership : 100 Shares own by partnership , as W's 100 shares are attributed to A and A's 100 Shares are reattributed to Partnership

B, C, and D does not owns any shares of Yancy as no reattribution to other partners .

Xerxes contructively owns 100 Shares which is reattributed to Partnership .

Please Repost the 1st Question again as i am not able to connect the Picture half Question with your Written Question .