C and D organized Z Corporation 10 years ago, each contributing $40,000 and each receiving 400 shares of common stock. Five years ago, in June, Z declared a one for one dividend payable in pure preferred with a $400 fair market value. The value of the common stock after the distribution was $1,600 per share. In that year, five years ago, Z had accumulated E&P of $52,000 and current E&P of $12,000. In the current year, Z has accumulated E&P of $112,000 and current E&P of $8,000. In December of the current year, C sells all of his preferred stock to E for $36,000. In June of that same year, C had previously sold all of his common stock to F for $200,000. E is C’s son. Same facts as Question 7, except in the current year Z redeems all of C’s preferred stock in exchange for $36,000. a. 306 does not apply to this transaction. The entire $36,000 is ordinary income. b. 306 does not apply to this transaction. Of the redemption proceeds, $32,000 is ordinary income. c. 306 does not apply because of the complete termination of the preferred stock interest. d. None of the above.
C and D organized Z Corporation 10 years ago, each contributing $40,000 and each receiving 400 shares of common stock. Five years ago, in June, Z declared a one for one dividend payable in pure preferred with a $400 fair market value. The value of the common stock after the distribution was $1,600 per share. In that year, five years ago, Z had accumulated E&P of $52,000 and current E&P of $12,000. In the current year, Z has accumulated E&P of $112,000 and current E&P of $8,000. In December of the current year, C sells all of his
Same facts as Question 7, except in the current year Z redeems all of C’s preferred stock in exchange for $36,000.
a. |
306 does not apply to this transaction. The entire $36,000 is ordinary income. |
|
b. |
306 does not apply to this transaction. Of the redemption proceeds, $32,000 is ordinary income. |
|
c. |
306 does not apply because of the complete termination of the preferred stock interest. |
|
d. |
None of the above. |
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