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2. Green, Inc., a C corporation, distributes a tract of land held as an investment (FMV S500,000, basis $220,000) and its mor
Sns soe (gain/loss) What is Susans tax liability/benefit as a result of the redemption? Assume she has sufficient long-term
2. Green, Inc., a C corporation, distributes a tract of land held as an investment (FMV S500,000, basis $220,000) and its mortgage of $550,000 to Susan in return for 50 of her shares at the end of the year. Green, Inc. has a current E&P of $190,000 for the year, and started the year an accumulated E & P of $60,000. Green's marginal tax rate is 21%. Susan has an individual marginal tax rate of 33% and both a dividend and a long-term capital gains tax rate of 15%. Susan owns 200 of Green's 1,000 shares outstanding and her basis in her Green stock is $20,000. Susan has held her stock for two years. The distribution is a qualified stock redemption. a. What is Green's recognized gain on the distribution? b. What is the increase in Green's tax liability as a result of the distribution? c. What is Green's ending E&P (after the redemption)? d. What is the amount of Susan's distribution?
Sns soe (gain/loss) What is Susan's tax liability/benefit as a result of the redemption? Assume she has sufficient long-term capital gains from the sale of other stock. f. (liability/benefit) g. What is Susan's basis in the land? h. What is Susan's basis in her remaining Green stock?
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Answer #1

I am answering first 4 sub-questions.

a. Green's Recognized Gain on distribution = Liabilities given up + Basis of shares exchanged - FMV of the Investment

                                                                     = $550,000 - $5,000* - $500,000

                                                                     = $55,000

* Basis of share exchanged = (Basis of 20000 Shares / No of shares) * No of shares exchanged

                                             = ($20,000/200) * 50 = $100 * 50 = $5,000

b. Increase in Tax Liability for Green = Recognized Gain * Marginal tax rate

                                            = $55,000 * 21%

                                                          = $11,550

c. Green's ending E&P (after redemption)

A Mortgage given up $        550,000
B (+) Value of shares exchanged $            5,000
C (-) Basis of Investment $        220,000
D E&P (A+B-C) $        335,000
E (+) Accumulated E&P $          60,000
F (+) Current E&P for the year $        190,000
G Green's ending E&P after redemption (D+E+F) $        585,000

d. Susan's distribution amount = Mortgage given up + Basis of shares exchanged

                                                  = $550,000 + $5,000

                                                  = $555,000

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