oday I advised the president of Crane Corporation regarding his November 25 letter. Crane Corporation had 2,000 shares of stock outstanding. It redeemed 500 shares for $370,000, when it had paid-in capital of $300,000 and E & P of $1,200,000. The edemption qualifies for sale or exchange treatment for the shareholder. Crane incurred $13,000 of accounting and legal fees with respect to the redemption

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Q 4.

 

DATE: December 2, 2021
FROM: Astia Jackson.
TAX FILE MEMORANDUM
SUBJECT: Crane Corporation
Today I advised the president of Crane Corporation regarding his November 25 letter. Crane Corporation had 2,000 shares of
stock outstanding. It redeemed 500 shares for $370,000, when it had paid-in capital of $300,000 and E & P of $1,200,000. The
redemption qualifies for sale or exchange treatment for the shareholder. Crane incurred $13,000 of accounting and legal fees with
respect to the redemption transaction and $18,500 of interest expense on debt incurred to finance the redemption.
At Issue: What is the change in Crane Corporation's E & P as a result of the redemption? Also, are the redemption expenditures
deductible by Crane?
Conclusion: Under § 312(n)(7), the E & P account of a corporation is
by a qualifying stock redemption in
an amount not in excess of the ratable share of the E & P of the distributing corporation attributable to the stock redeemed. Since
Crane Corporation redeemed
Code 5 162(k) specifically
% of its stock, the change in E & P is s
a deduction for redemption expenditures. "
Transcribed Image Text:DATE: December 2, 2021 FROM: Astia Jackson. TAX FILE MEMORANDUM SUBJECT: Crane Corporation Today I advised the president of Crane Corporation regarding his November 25 letter. Crane Corporation had 2,000 shares of stock outstanding. It redeemed 500 shares for $370,000, when it had paid-in capital of $300,000 and E & P of $1,200,000. The redemption qualifies for sale or exchange treatment for the shareholder. Crane incurred $13,000 of accounting and legal fees with respect to the redemption transaction and $18,500 of interest expense on debt incurred to finance the redemption. At Issue: What is the change in Crane Corporation's E & P as a result of the redemption? Also, are the redemption expenditures deductible by Crane? Conclusion: Under § 312(n)(7), the E & P account of a corporation is by a qualifying stock redemption in an amount not in excess of the ratable share of the E & P of the distributing corporation attributable to the stock redeemed. Since Crane Corporation redeemed Code 5 162(k) specifically % of its stock, the change in E & P is s a deduction for redemption expenditures. "
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