Parrot Corporation is a closely held company with accumulated E & P of $300,000 and current E & P of $350,000. Tom and Jerry are brothers; each owns a 50% share in Parrot, and they share management responsibilities equally. What are the tax consequences of each of the following independent transactions involving Parrot, Tom, and Jerry? How does each transaction affect Parrot's E & P?
See attached. 5-46
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a:
Realized loss : Basis – Fair market Value : $350,000 - $300,000 = $50,000. But it cannot be recognized by the parrot corporation due to the section 267. But E&P for Parrot Corporation would be reduced by $75,000 ($50,000 + $25,000)
Constructive Dividend = Fair market value – Selling Price to Tom = $300,000 - $275,000 = $25,000
Parrot has is a ($50,000) realized loss of which $0 is recognized. In additions, there is a $25,000 constructive dividend. As a result, E&P is reduced by $75,000.
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