Deck 18: Corporate Taxation: Nonliquidating Distributions

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Question
Only taxable income and deductible expenses are included in the computation of currentearnings and profits.
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Question
Diego owns 30 percent of Azul Corporation. Azul Corporation owns 50 percent of Verde Corporation. Under the attribution rules applying to stock redemptions, Diego is treated as owning 15 percent of Verde Corporation.
Question
Siblings are considered "family" under the stock attribution rules that apply to stock redemptions.
Question
The term "earnings and profits" is well defined in the Internal Revenue Code.
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A stock redemption is always treated as a sale or exchange for tax purposes.
Question
The "double taxation" of corporate income refers to the taxation of corporate income atboth the entity-level and the shareholder-level.
Question
Green Corporation has negative current earnings and profits of ($100,000) and positiveaccumulated earnings and profits of $250,000. A $50,000 distribution from Green to its sole shareholder will be treated as a dividend because total earnings and profits is apositive $150,000.
Question
Cedar Corporation incurs a net capital loss of $20,000 in 20X3 that cannot be deductedon its income tax return but must be carried forward to 20X4. However, Cedar will deduct the net capital loss in the computation of current earnings and profits for 20X3.
Question
Evergreen Corporation distributes land with a fair market value of $50,000 to its sole shareholder. Evergreen's tax basis in the land is $200,000. Evergreen will report a tax loss of $150,000 on the distribution regardless of whether its earnings and profits are positive or negative.
Question
A corporation's "earnings and profits" account is equal to the company's "retainedearnings" account on its balance sheet.
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A distribution from a corporation to a shareholder will always be treated as a dividendfor tax purposes.
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Green Corporation has current earnings and profits of $100,000 and negativeaccumulated earnings and profits of ($200,000). A $50,000 distribution from Green to its sole shareholder will not be treated as a dividend because total earnings and profits is a negative $100,000.
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Tammy owns 60 percent of the stock of Huron Corporation. Unrelated individuals own the remaining 40 percent. For a stock redemption to be treated as an exchange under the "substantially disproportionate" rule, the redemption must reduce Tammy's stockownership in Huron Corporation below 48 percent.
Question
Terrapin Corporation incurs federal income taxes of $250,000 in 20X3. Terrapin deducts the federal income taxes in computing its current earnings and profits for 20X3.
Question
The recipient of a taxable stock dividend will have a tax basis in the stock equal to the fair market value of the stock received.
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Evergreen Corporation distributes land with a fair market value of $200,000 to its sole shareholder. Evergreen's tax basis in the land is $50,000. Assuming sufficient earnings and profits, the amount of dividend reported by the shareholder is $200,000.
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Stock dividends are always tax-free to the recipient shareholder.
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A distribution from a corporation to a shareholder will only be treated as a dividend fortax purposes if the distribution is paid out of current or accumulated earnings and profits.
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The recipient of a tax-free stock dividend will have a zero tax basis in the stock.
Question
Evergreen Corporation distributes land with a fair market value of $200,000 to its sole shareholder. Evergreen's tax basis in the land is $50,000. Evergreen will report a gain of$150,000 on the distribution regardless of whether its earnings and profits are positive or negative.
Question
Aztec Company reports current E&P of $200,000 in 20X3 and accumulated E&P at the beginning of the year of negative $100,000. Aztec distributed $300,000 to its soleshareholder on January 1, 20X3. How much of the distribution is treated as a dividend in20X3?

A) $100,000.
B) $300,000.
C) $0.
D) $200,000.
Question
A distribution in partial liquidation of a corporation is always treated as a sale or exchange by an individual shareholder.
Question
Which of the following statements best describes current earnings and profits?

A) Current earnings and profits is another name for a corporation's retained earnings on its balance sheet.
B) Current earnings and profits is a conceptual tax concept with no definition in the Internal Revenue Code.
C) Current earnings and profits is a precisely defined tax term in the Internal Revenue Code and represents a corporation's economic income.
D) Current earnings and profits is an ill-defined tax concept in the Internal Revenue Code and represents a corporation's economic income.
Question
Bruin Company reports current E&P of $200,000 in 20X3 and accumulated E&P at the beginning of the year of $100,000. Bruin distributed $400,000 to its sole shareholder on January 1, 20X3. How much of the distribution is treated as a dividend in 20X3?

A) $200,000.
B) $100,000.
C) $400,000.
D) $300,000.
Question
Which statement best describes the concept of the "double taxation" of corporation income?

A) Corporate income is subject to two levels of taxation: at the federal level and a second time at the state level.
B) Corporate income is taxed twice at the corporate level: first when earned and then a second time if appreciated property is distributed to a shareholder.
C) Corporate income is taxed when earned by a C corporation and then a second time at the shareholder level when distributed as a dividend.
D) Corporate income is subject to two levels of taxation: the regular tax and the alternative minimum tax.
Question
Grand River Corporation reported taxable income of $500,000 in 20X3 and paid federal income taxes of $170,000. Not included in the computation was a disallowed meals and entertainment expense of $2,000, tax-exempt income of $1,000, and deferred gain on a current year transaction treated as an installment sale of $25,000. The corporation'scurrent earnings and profits for 20X3 would be:

A) $524,000.
B) $500,000.
C) $331,000.
D) $354,000.
Question
Which of the following forms of earnings distributions would not be subject to double taxation at the corporate and shareholder level?

A) Partial liquidation.
B) Dividend.
C) Stock redemption.
D) Compensation paid to a shareholder/employee of the corporation.
Question
Which of the following statements best describes the role of current and accumulated earnings and profits in determining if a distribution is a dividend?

A) A distribution will never be a dividend if current earnings and profits for the year are negative, even if accumulated earnings and profits is positive.
B) A distribution will only be a dividend if total earnings and profits (current plus accumulated) is positive at the time of the distribution.
C) At a minimum, some portion of the distribution will be a dividend if current earnings and profits for the year are positive, even if accumulated earnings and profits are negative.
D) A distribution can never be a dividend if current earnings and profits are negative.
Question
Packard Corporation reported taxable income of $1,000,000 in 20X3 and paid federal income taxes of $340,000. Included in the taxable income computation was a dividends received deduction of $5,000, a net capital loss carryover from 20X2 of $10,000 utilized in 20X3, and gain of $50,000 recognized on the collection of cash from an installment sale that took place in 20X1. The corporation's current earnings and profits for 20X3 would be:

A) $675,000.
B) $1,015,000.
C) $625,000.
D) $965,000.
Question
Au Sable Corporation reported taxable income of $800,000 in 20X3 and paid federalincome taxes of $272,000. Not included in the computation was a disallowed penalty of$25,000, life insurance proceeds of $100,000, and a Federal income tax refund from20X2 of $50,000. Au Sable is an accrual basis taxpayer. The corporation's current earnings and profits for 20X3 would be:

A) $553,000.
B) $603,000.
C) $875,000.
D) $653,000.
Question
Oakland Corporation reported a net operating loss of $500,000 in 20X3 and elected to carry the loss forward to 20X4. Not included in the computation was a disallowed meals and entertainment expense of $20,000, tax-exempt income of $10,000, and deferred gain on a current year transaction treated as an installment sale of $250,000. The corporation's current earnings and profits for 20X3 would be:

A) ($260,000).
B) ($510,000).
C) ($720,000).
D) ($500,000).
Question
Battle Corporation redeems 20 percent of its stock for $100,000 in a stock redemption that is treated as an exchange by the shareholders. Battle's E&P at the date of theredemption is $200,000. Battle must reduce its earnings and profits by $100,000 because of the redemption.
Question
Which of the following statements best describes the priority of the tax treatment of a distribution from a corporation to a shareholder?

A) The distribution is a return of capital, then gain from sale of stock, and finally a dividend to the extent of the corporation's earnings and profits.
B) The distribution is a return of capital, then a dividend to the extent of the corporation's earnings and profits, and finally gain from sale of stock.
C) The shareholder can elect to treat the distribution as either a dividend to the extent of the corporation's earnings and profits or a return of capital, followed by gain from sale of stock.
D) The distribution is a dividend to the extent of the corporation's earnings and profits, then a return of capital, and finally gain from sale of stock.
Question
Madison Corporation reported taxable income of $400,000 in 20X3 and accrued federal income taxes of $136,000. Included in the computation of taxable income was regular depreciation of $200,000 (E&P depreciation is $60,000) and a net capital loss carryover of $20,000 from 20X2 utilized in 20X3. The corporation's current earnings and profits for 20X3 would be:

A) $380,000.
B) $424,000.
C) $404,000.
D) $344,000.
Question
Abbot Corporation reported a net operating loss of $400,000 in 20X3, which the corporation elected to carryforward to 20X4. Included in the computation of the loss was regular depreciation of $100,000 (E&P depreciation is $40,000), first year expensingunder §179 of $50,000, and a dividends received deduction of $10,000. The corporation's current earnings and profits for 20X3 would be:

A) ($290,000).
B) ($490,000).
C) ($330,000).
D) ($400,000).
Question
Which of these items is not an adjustment to taxable income or net loss to compute current E&P?

A) Net capital loss carryforward utilized in the current year from the prior year tax return.
B) Refund of prior year taxes for an accrual method taxpayer.
C) Dividends received deduction.
D) Tax-exempt income.
Question
A calendar-year corporation has negative current E&P of $500 and accumulated positive E&P of $1,000. The corporation makes a $600 distribution to its sole shareholder. Which of the following statements is true?

A) Up to $600 of the distribution could be a dividend depending on the balance in accumulated earnings and profits on the date of the distribution.
B) $0 of the distribution will be a dividend because current earnings and profits are negative.
C) $500 of the distribution will be a dividend because total earnings and profits is $500.
D) $600 of the distribution will be a dividend because accumulated earnings and profits is $1,000.
Question
The "family attribution" rules are automatically waived in a complete redemption of a shareholder's stock.
Question
Greenwich Corporation reported a net operating loss of $800,000 in 20X3, which the corporation elected to carryforward to 20X4. The computation of the loss did not include a disallowed fine of $50,000, life insurance proceeds of $500,000, and a current yearcharitable contribution of $10,000 that will be carried forward to 20X4. The corporation's current earnings and profits for 20X3 would be:

A) ($250,000).
B) ($360,000).
C) ($300,000).
D) ($260,000).
Question
A calendar-year corporation has positive current E&P of $500 and accumulated negative E&P of $1,200. The corporation makes a $400 distribution to its sole shareholder. Which of the following statements is true?

A) The distribution may be a dividend, depending on whether total earnings and profits at the date of the distribution is positive.
B) The distribution will be a dividend because current earnings and profits are positive and exceed the distribution.
C) The distribution will not be a dividend because total earnings and profits is a negative $700.
D) A distribution from a corporation to a shareholder is always a dividend, regardless of the balance in earnings and profits.
Question
Longhorn Company reports current E&P of $100,000 in 20X3 and accumulated E&P at the beginning of the year of negative $200,000. Longhorn distributed $300,000 to its sole shareholder on January 1, 20X3. The shareholder's tax basis in his stock in Longhorn is$100,000. How is the distribution treated by the shareholder in 20X3?

A) $300,000 dividend.
B) $0 dividend, $100,000 tax-free return of basis, and $200,000 capital gain.
C) $100,000 dividend and $200,000 tax-free return of basis.
D) $100,000 dividend, $100,000 tax-free return of basis, and $100,000 capital gain.
Question
Paladin Corporation had current and accumulated E&P of $500,000 at December 31,20X3. On December 31, the company made a distribution of land to its sole shareholder, Maria Mendez. The land's fair market value was $200,000 and its tax and E&P basis to Paladin was $250,000. Maria assumed a liability of $25,000 attached to the land. The tax consequences of the distribution to Paladin in 20X3 would be:

A) No loss recognized and a reduction in E&P of $225,000.
B) $50,000 loss recognized and a reduction in E&P of $200,000.
C) No loss recognized and a reduction in E&P of $200,000.
D) $50,000 loss recognized and a reduction in E&P of $225,000.
Question
Montclair Corporation had current and accumulated E&P of $500,000 at December 31,20X3. On December 31, the company made a distribution of land to its sole shareholder, Molly Pitcher. The land's fair market value was $200,000 and its tax and E&P basis to Montclair was $50,000. Molly assumed a liability of $25,000 attached to the land. The tax consequences of the distribution to Montclair in 20X3 would be:

A) No gain recognized and a reduction in E&P of $175,000.
B) $150,000 gain recognized and a reduction in E&P of $175,000.
C) No gain recognized and a reduction in E&P of $200,000.
D) $150,000 gain recognized and a reduction in E&P of $200,000.
Question
Which of the following payments could be treated as a constructive dividend by the IRS?

A) Interest paid to a shareholder/creditor.
B) End-of-year bonus payment to a shareholder/employee.
C) Rent paid to a shareholder/lessor.
D) All of these payments could be treated as a constructive dividend by the IRS
Question
Tar Heel Corporation had current and accumulated E&P of $500,000 at December 3120X3. On December 31, the company made a distribution of land to its sole shareholder, William Roy. The land's fair market value was $100,000 and its tax and E&P basis to Tar Heel was $25,000. William assumed a mortgage attached to the land of $10,000. The tax consequences of the distribution to William in 20X3 would be:

A) $100,000 dividend and a tax basis in the land of $90,000.
B) Dividend of $90,000 and a tax basis in the land of $90,000.
C) Dividend of $90,000 and a tax basis in the land of $100,000.
D) $100,000 dividend and a tax basis in the land of $100,000.
Question
Catamount Company had current and accumulated E&P of $500,000 at December 31,20X3. On December 31, the company made a distribution of land to its sole shareholder, Caroline West. The land's fair market value was $200,000 and its tax and E&P basis to Catamount was $250,000. The tax consequences of the distribution to Catamount in20X3 would be:

A) No loss recognized and a reduction in E&P of $250,000.
B) $50,000 loss recognized and a reduction in E&P of $150,000.
C) No loss recognized and a reduction in E&P of $200,000.
D) $50,000 loss recognized and a reduction in E&P of $250,000.
Question
Inca Company reports current E&P of negative $100,000 in 20X3 and accumulated E&P at the beginning of the year of $200,000. Inca distributed $300,000 to its sole shareholder on January 1, 20X3. How much of the distribution is treated as a dividend in 20X3?

A) $300,000.
B) $100,000.
C) $0.
D) $200,000.
Question
Which of the following statements is true?

A) A stock redemption not treated as an exchange will automatically be treated as a taxable dividend.
B) All stock redemptions are treated as exchanges for tax purposes.
C) All stock redemptions are treated as dividends if received by an individual.
D) A stock redemption is treated as an exchange only if it meets one of three stock ownership tests described in the Internal Revenue Code.
Question
Husker Corporation reports current E&P of negative $200,000 in 20X3 and accumulated E&P at the beginning of the year of $300,000. Husker distributed $200,000 to its sole shareholder on December 31, 20X3. The shareholder's tax basis in her stock in Husker is$50,000. How is the distribution treated by the shareholder in 20X3?

A) $100,000 dividend and $100,000 tax-free return of basis.
B) $200,000 dividend.
C) $0 dividend, $50,000 tax-free return of basis, and $150,000 capital gain.
D) $100,000 dividend, $50,000 tax-free return of basis, and $50,000 capital gain.
Question
Cavalier Corporation had current and accumulated E&P of $500,000 at December 3120X3. On December 31, the company made a distribution of land to its sole shareholder, Tom Jefferson. The land's fair market value was $200,000 and its tax and E&P basis to Cavalier was $50,000. The tax consequences of the distribution to Cavalier in 20X3 would be:

A) No gain recognized and a reduction in E&P of $200,000.
B) $150,000 gain recognized and a reduction in E&P of $50,000.
C) No gain recognized and a reduction in E&P of $50,000.
D) $150,000 gain recognized and a reduction in E&P of $200,000.
Question
Beaver Company reports current E&P of $100,000 in 20X3 and accumulated E&P at the beginning of the year of $200,000. Beaver distributed $400,000 to its sole shareholder on January 1, 20X3. The shareholder's tax basis in her stock in Beaver is $200,000. How is the distribution treated by the shareholder in 20X3?

A) $100,000 dividend, $200,000 tax-free return of basis, and $100,000 capital gain.
B) $200,000 dividend and $200,000 tax-free return of basis.
C) $300,000 dividend and $100,000 tax-free return of basis.
D) $400,000 dividend.
Question
Sara owns 60 percent of the stock of Lea Corporation. Unrelated individuals own theremaining 40 percent. For a stock redemption of Sara's stock to be treated as an exchange under the "substantially disproportionate" test, what percentage of Lea stock must Sara own after the redemption?

A) Any percentage less than 48 percent.
B) Any percentage less than 50 percent.
C) Any percentage less than 60 percent.
D) All stock redemptions involving individuals are treated as exchanges.
Question
Which of the following individuals is not considered "family" for purposes of applying the stock attribution rules to a stock redemption?

A) Grandparents.
B) Spouse.
C) Grandchildren.
D) Parents.
Question
Wildcat Corporation reports current E&P of negative $200,000 in 20X3 and accumulated E&P at the beginning of the year of $100,000. Wildcat distributed $300,000 to its sole shareholder on December 31, 20X3. How much of the distribution is treated as adividend in 20X3?

A) $0.
B) $300,000.
C) $100,000.
D) $200,000.
Question
Wonder Corporation declared a common stock dividend to all shareholders of record on September 30, 20X3. Shareholders will receive three shares of Wonder stock for each five shares of stock they already own. Diana owns 300 shares of Wonder stock with a tax basis of $90 per share (a total basis of $27,000). The fair market value of the Wonderstock was $180.00 per share on September 30, 20X3. What are the tax consequences of the stock dividend to Diana?

A) $10,800 dividend and a tax basis in the new stock of $180.00 per share.
B) $0 dividend income and a tax basis in the new stock of $56.25 per share.
C) $0 dividend income and a tax basis in the new stock of $67.50 per share.
D) $0 dividend income and a tax basis in the new stock of $180.00 per share.
Question
Sam owns 70 percent of the stock of Club Corporation. Unrelated individuals own theremaining 30 percent. For a stock redemption of Sam's stock to be treated as an exchange under the "substantially disproportionate" test, what percentage of Club stock must Sam own after the redemption?

A) Any percentage less than 50 percent.
B) Any percentage less than 56 percent.
C) Any percentage less than 70 percent.
D) All stock redemptions involving individuals are treated as exchanges.
Question
Which of the following stock dividends would be tax-free to the shareholder?

A) A 2-for-1 stock split to all holders of common stock.
B) A stock dividend to all holders of preferred stock.
C) A stock dividend where the shareholder could choose between cash and stock.
D) A 2-for-1 stock split to all holders of common stock and a stock dividend to all holders of preferred stock are tax-free to the shareholder.
Question
El Toro Corporation declared a common stock dividend to all shareholders of record on June 30, 20X3. Shareholders will receive 1 share of El Toro stock for each 2 shares of stock they already own. Raoul owns 300 shares of El Toro stock with a tax basis of $60 per share. The fair market value of the El Toro stock was $100 per share on June 30,20X3. What are the tax consequences of the stock dividend to Raoul?

A) $0 dividend income and a tax basis in the new stock of $60 per share.
B) $15,000 dividend and a tax basis in the new stock of $100 per share.
C) $0 dividend income and a tax basis in the new stock of $100 per share.
D) $0 dividend income and a tax basis in the new stock of $40 per share.
Question
Which of the following factors would not be considered in determining if compensation paid to a shareholder/employee is reasonable?

A) The individual's marginal income tax rate.
B) The individual's duties and responsibilities.
C) What individuals performing in comparable capacities at other companies are paid.
D) Whether the corporation has a formal compensation policy.
Question
Which of the following statements is not considered a potential answer to the question of why corporations pay dividends?

A) Paying dividends avoids the double taxation of corporate income.
B) Dividends are a signal to the capital markets about the health of a corporation's activities.
C) Paying dividends is a source of investor goodwill.
D) Demanding that managers pay out dividends restricts their investment activities and forces them to adopt more efficient investment policies.
Question
General Inertia Corporation made a pro rata distribution of $50,000 to Tiara, Inc. in partial liquidation of the company on December 31, 20X3. Tiara, Inc. owns 500 shares (50%) of General Inertia. The distribution was in exchange for 250 shares of Tiara's stock in the company. After the partial liquidation, Tiara continued to own 50% of the remaining stock in General Inertia. At the time of the distribution, the shares had a fair market value of $200 per share. Tiara's income tax basis in the shares was $100 per share. General Inertia had total E&P of $800,000 at the time of the distribution. What amount of dividend or capital gain does Tiara recognize because of the transaction?

A) Tiara recognizes dividend income of $50,000.
B) Tiara recognizes capital gain of $50,000.
C) Tiara does not recognize any dividend income or capital gain.
D) Tiara recognizes capital gain of $25,000.
Question
Viking Corporation is owned equally by Sven and his wife Olga, each of whom hold 100 shares in the company. Viking redeemed 75 shares of Sven's stock in the company on December 31, 20X3. Viking paid Sven $2,000 per share. His income tax basis in each share is $1,000. Viking has total E&P of $500,000. What are the tax consequences to Sven because of the stock redemption?

A) $75,000 capital gain and a tax basis in each of his remaining shares of $1,000.
B) $150,000 dividend and a tax basis in each of his remaining shares of $1,000.
C) $150,000 dividend and a tax basis in each of his remaining shares of $4,000.
D) $75,000 capital gain and a tax basis in each of his remaining shares of $2,000.
Question
St. Clair Company reports positive current E&P of $500,000 in 20X3 and positive accumulated E&P at the beginning of the year of $400,000. St. Clair Company distributed $600,000 to its sole shareholder, Danielle Brush on December 31, 20X3. Danielle's tax basis in her St. Clair stock is$120,000. How much of the $600,000 distribution is treated as a dividend to Danielle and what is her basis in St. Clair stock after the distribution?
Question
Panda Company is owned equally by Min, her husband Bin, her sister Xiao, and her grandson, Han, each of whom hold 100 shares in the company. Under the family attribution rules, how many shares of Panda stock is Min deemed to own?

A) 100.
B) 400.
C) 200.
D) 300.
Question
Viking Corporation is owned equally by Sven and his wife Olga, each of whom hold 100 shares in the company. Viking redeemed 75 shares of Sven's stock for $2,000 per share on December 31, 20X3. Viking has total E&P of $500,000. What are the taxconsequences to Viking because of the stock redemption?

A) A reduction of $187,500 in E&P because of the exchange.
B) A reduction of $375,000 in E&P because of the exchange.
C) No reduction in E&P because of the exchange.
D) A reduction of $150,000 in E&P because of the exchange.
Question
Comet Company is owned equally by Pat and his sister Pam, each of whom hold 100 shares in the company. Comet redeems 50 of Pam's shares on December 31, 20X3, for$1,000 per share in a transaction that Pam treats as an exchange for tax purposes. Comet has total E&P of $160,000 on December 31, 20X3. What are the tax consequences to Comet because of the stock redemption?

A) A reduction of $50,000 in E&P because of the exchange.
B) A reduction of $80,000 in E&P because of the exchange.
C) A reduction of $40,000 in E&P because of the exchange.
D) No reduction in E&P because of the exchange.
Question
Comet Company is owned equally by Pat and his sister Pam, each of whom hold 100 shares in the company. Comet redeems 50 of Pam's shares on December 31, 20X3, for$1,000 per share in a transaction that Pam treats as an exchange for tax purposes. Comet has total E&P of $250,000 on December 31, 20X3. What are the tax consequences to Comet because of the stock redemption?

A) No reduction in E&P because of the exchange.
B) A reduction of $125,000 in E&P because of the exchange.
C) A reduction of $62,500 in E&P because of the exchange.
D) A reduction of $50,000 in E&P because of the exchange.
Question
Beltway Company is owned equally by George, his brother Thomas, and a partnership owned 50 percent by George and his father Abe. Each of the three shareholders holds100 shares in the company. Under the §318 stock attribution rules, how many shares ofBeltway stock is George deemed to own?

A) 150.
B) 100.
C) 300.
D) 200.
Question
Tammy owns 100 shares in Star Struck Corporation. The other 100 shares are owned by her husband Tommy. Which of the following statements is true?

A) A stock redemption that completely terminates Tammy's direct interest in a corporation will be treated as a dividend for tax purposes.
B) A stock redemption that completely terminates Tammy's direct interest in a corporation will be treated as an exchange for tax purposes.
C) A stock redemption that completely terminates Tammy's direct interest in a corporation will be treated as a dividend to the extent that the redemption exceeds
Tammy's tax basis in the redeemed shares.
D) A stock redemption that completely terminates Tammy's direct interest in a corporation will be treated as an exchange if Tammy waives the family attribution rules and files a "triple i" agreement with the IRS.
Question
Austin Company reports positive current E&P of $200,000 and negative accumulated E&P of$300,000. Austin distributed $250,000 to its sole shareholder, Betsy Bevo, on December 31, 20X3. Betsy' tax basis in her stock is $125,000. How much of the $250,000 distribution is treated as a dividend to Betsy and what is her tax basis in Austin stock after the distribution?
Question
Comet Company is owned equally by Pat and his sister Pam, each of whom hold 100 shares in the company. Pam wants to reduce her ownership in the company, and it was decided that the company will redeem 50 of her shares for $1,000 per share on December31, 20X3. Pam's income tax basis in each share is $500. Comet has total E&P of$250,000. What are the tax consequences to Pam because of the stock redemption?

A) $50,000 dividend and a tax basis in each of her remaining shares of $100.
B) $25,000 capital gain and a tax basis in each of her remaining shares of $500.
C) $25,000 capital gain and a tax basis in each of her remaining shares of $100.
D) $50,000 dividend and a tax basis in each of her remaining shares of $50.
Question
Lansing Company is owned equally by Jennifer, her husband Dan, and DeWitt Corporation, which is owned 50 percent by Jennifer and her sister Jane. Each of the three shareholders holds 100 shares in the company. Under the §318 stock attribution rules, how many shares of Lansing stock is Jennifer deemed to own?

A) 100.
B) 250.
C) 200.
D) 300.
Question
Loon, Inc. reported taxable income of $600,000 in 20X3 and paid federal income taxes of $202,000.Not included in the company's computation of taxable income is tax-exempt interest of $30,000, disallowed meals and entertainment expenses of $15,000, and disallowed expenses related to the tax-exempt income of $4,000. Loon deducted depreciation of $200,000 on its tax return. Under the alternative (E&P) depreciation method, the deduction would have been $80,000. Compute the company's current E&P for 20X3.
Question
Superior Corporation reported taxable income of $1,000,000 in 20X3. Superior paid a dividend of$100,000 to its sole shareholder, Mary Yooper. Superior Corporation is subject to a flat rate tax of34%. The dividend meets the requirements to be a "qualified dividend" and Mary is subject to a tax rate of 15% on the dividend. What is the total federal income tax imposed on the corporate income earned by Superior including taxes on the amount distributed to Mary as a dividend?
Question
Corona Company is owned equally by Maria, her sister Carlita, her mother Gabriella, and her grandmother Olivia, each of whom hold 100 shares in the company. Under the family attribution rules, how many shares of Corona stock is Maria deemed to own?

A) 400.
B) 100.
C) 300.
D) 200.
Question
Erie Corporation reported taxable income of $2,200,000 in 20X3 before any deduction for anypayment to its sole shareholder and employee, LaBron Cleveland. Erie paid a bonus of $200,000 toLaBron at year-end. Erie Corporation is subject to a flat-rate tax of 34%. The bonus meets therequirements to be "reasonable" and is therefore deductible by Erie. LaBron is subject to a marginal tax rate of 35% on the bonus. What is the total federal income tax imposed on the corporate income earned by Erie and paid to LaBron as a bonus?
Question
Elk Company reports negative current E&P of $200,000 and positive accumulated E&P of$300,000. Elk distributed $200,000 to its sole shareholder, Barney Rubble, on December 31, 20X3. Barney's tax basis in his Elk stock is $75,000. What is the tax treatment of the distribution to Barney and what is his tax basis in Elk stock after the distribution?
Question
Houghton Company reports negative current E&P of ($500,000) and negative accumulated E&P of($800,000). Houghton distributed $100,000 to its sole shareholder, Blossom Applegate, on December 31, 20X3. Blossom's tax basis in her Houghton stock is $50,000. What is the tax treatment of the distribution to Blossom and what is her tax basis in Houghton stock after the distribution?
Question
Lansing Company is owned equally by Jennifer, her husband Dan, and DeWitt Corporation, which is owned 50 percent by Jennifer and her sister Jane. Each of the three shareholders holds 100 shares in the company. Under the §318 stock attribution rules, how many shares of Lansing stock is DeWitt Corporation deemed to own?

A) 200.
B) 300.
C) 100.
D) 250.
Question
General Inertia Corporation made a distribution of $50,000 to Henry Tiara in partial liquidation of the company on December 31, 20X3. Henry owns 500 shares (50%) of General Inertia. The distribution was in exchange for 250 shares of Henry's stock in the company. After the partial liquidation, Henry continued to own 50% of the remainingstock in General Inertia. At the time of the distribution, the shares had a fair market value of $200 per share. Henry's income tax basis in the shares was $100 per share. GeneralInertia had total E&P of $800,000 at the time of the distribution. What are the taxconsequences to Henry because of the transaction?

A) Henry has dividend income of $50,000 and a tax basis in his remaining shares of $200 per share.
B) Henry has capital gain of $25,000 and a tax basis in his remaining shares of $200 per share.
C) Henry has capital gain of $25,000 and a tax basis in his remaining shares of $100 per share.
D) Henry has dividend income of $50,000 and a tax basis in his remaining shares of $100 per share.
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Deck 18: Corporate Taxation: Nonliquidating Distributions
1
Only taxable income and deductible expenses are included in the computation of currentearnings and profits.
False
2
Diego owns 30 percent of Azul Corporation. Azul Corporation owns 50 percent of Verde Corporation. Under the attribution rules applying to stock redemptions, Diego is treated as owning 15 percent of Verde Corporation.
False
3
Siblings are considered "family" under the stock attribution rules that apply to stock redemptions.
False
4
The term "earnings and profits" is well defined in the Internal Revenue Code.
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5
A stock redemption is always treated as a sale or exchange for tax purposes.
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6
The "double taxation" of corporate income refers to the taxation of corporate income atboth the entity-level and the shareholder-level.
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7
Green Corporation has negative current earnings and profits of ($100,000) and positiveaccumulated earnings and profits of $250,000. A $50,000 distribution from Green to its sole shareholder will be treated as a dividend because total earnings and profits is apositive $150,000.
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8
Cedar Corporation incurs a net capital loss of $20,000 in 20X3 that cannot be deductedon its income tax return but must be carried forward to 20X4. However, Cedar will deduct the net capital loss in the computation of current earnings and profits for 20X3.
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9
Evergreen Corporation distributes land with a fair market value of $50,000 to its sole shareholder. Evergreen's tax basis in the land is $200,000. Evergreen will report a tax loss of $150,000 on the distribution regardless of whether its earnings and profits are positive or negative.
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10
A corporation's "earnings and profits" account is equal to the company's "retainedearnings" account on its balance sheet.
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11
A distribution from a corporation to a shareholder will always be treated as a dividendfor tax purposes.
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12
Green Corporation has current earnings and profits of $100,000 and negativeaccumulated earnings and profits of ($200,000). A $50,000 distribution from Green to its sole shareholder will not be treated as a dividend because total earnings and profits is a negative $100,000.
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13
Tammy owns 60 percent of the stock of Huron Corporation. Unrelated individuals own the remaining 40 percent. For a stock redemption to be treated as an exchange under the "substantially disproportionate" rule, the redemption must reduce Tammy's stockownership in Huron Corporation below 48 percent.
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14
Terrapin Corporation incurs federal income taxes of $250,000 in 20X3. Terrapin deducts the federal income taxes in computing its current earnings and profits for 20X3.
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15
The recipient of a taxable stock dividend will have a tax basis in the stock equal to the fair market value of the stock received.
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16
Evergreen Corporation distributes land with a fair market value of $200,000 to its sole shareholder. Evergreen's tax basis in the land is $50,000. Assuming sufficient earnings and profits, the amount of dividend reported by the shareholder is $200,000.
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17
Stock dividends are always tax-free to the recipient shareholder.
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18
A distribution from a corporation to a shareholder will only be treated as a dividend fortax purposes if the distribution is paid out of current or accumulated earnings and profits.
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19
The recipient of a tax-free stock dividend will have a zero tax basis in the stock.
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20
Evergreen Corporation distributes land with a fair market value of $200,000 to its sole shareholder. Evergreen's tax basis in the land is $50,000. Evergreen will report a gain of$150,000 on the distribution regardless of whether its earnings and profits are positive or negative.
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21
Aztec Company reports current E&P of $200,000 in 20X3 and accumulated E&P at the beginning of the year of negative $100,000. Aztec distributed $300,000 to its soleshareholder on January 1, 20X3. How much of the distribution is treated as a dividend in20X3?

A) $100,000.
B) $300,000.
C) $0.
D) $200,000.
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22
A distribution in partial liquidation of a corporation is always treated as a sale or exchange by an individual shareholder.
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23
Which of the following statements best describes current earnings and profits?

A) Current earnings and profits is another name for a corporation's retained earnings on its balance sheet.
B) Current earnings and profits is a conceptual tax concept with no definition in the Internal Revenue Code.
C) Current earnings and profits is a precisely defined tax term in the Internal Revenue Code and represents a corporation's economic income.
D) Current earnings and profits is an ill-defined tax concept in the Internal Revenue Code and represents a corporation's economic income.
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24
Bruin Company reports current E&P of $200,000 in 20X3 and accumulated E&P at the beginning of the year of $100,000. Bruin distributed $400,000 to its sole shareholder on January 1, 20X3. How much of the distribution is treated as a dividend in 20X3?

A) $200,000.
B) $100,000.
C) $400,000.
D) $300,000.
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25
Which statement best describes the concept of the "double taxation" of corporation income?

A) Corporate income is subject to two levels of taxation: at the federal level and a second time at the state level.
B) Corporate income is taxed twice at the corporate level: first when earned and then a second time if appreciated property is distributed to a shareholder.
C) Corporate income is taxed when earned by a C corporation and then a second time at the shareholder level when distributed as a dividend.
D) Corporate income is subject to two levels of taxation: the regular tax and the alternative minimum tax.
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26
Grand River Corporation reported taxable income of $500,000 in 20X3 and paid federal income taxes of $170,000. Not included in the computation was a disallowed meals and entertainment expense of $2,000, tax-exempt income of $1,000, and deferred gain on a current year transaction treated as an installment sale of $25,000. The corporation'scurrent earnings and profits for 20X3 would be:

A) $524,000.
B) $500,000.
C) $331,000.
D) $354,000.
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27
Which of the following forms of earnings distributions would not be subject to double taxation at the corporate and shareholder level?

A) Partial liquidation.
B) Dividend.
C) Stock redemption.
D) Compensation paid to a shareholder/employee of the corporation.
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28
Which of the following statements best describes the role of current and accumulated earnings and profits in determining if a distribution is a dividend?

A) A distribution will never be a dividend if current earnings and profits for the year are negative, even if accumulated earnings and profits is positive.
B) A distribution will only be a dividend if total earnings and profits (current plus accumulated) is positive at the time of the distribution.
C) At a minimum, some portion of the distribution will be a dividend if current earnings and profits for the year are positive, even if accumulated earnings and profits are negative.
D) A distribution can never be a dividend if current earnings and profits are negative.
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29
Packard Corporation reported taxable income of $1,000,000 in 20X3 and paid federal income taxes of $340,000. Included in the taxable income computation was a dividends received deduction of $5,000, a net capital loss carryover from 20X2 of $10,000 utilized in 20X3, and gain of $50,000 recognized on the collection of cash from an installment sale that took place in 20X1. The corporation's current earnings and profits for 20X3 would be:

A) $675,000.
B) $1,015,000.
C) $625,000.
D) $965,000.
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30
Au Sable Corporation reported taxable income of $800,000 in 20X3 and paid federalincome taxes of $272,000. Not included in the computation was a disallowed penalty of$25,000, life insurance proceeds of $100,000, and a Federal income tax refund from20X2 of $50,000. Au Sable is an accrual basis taxpayer. The corporation's current earnings and profits for 20X3 would be:

A) $553,000.
B) $603,000.
C) $875,000.
D) $653,000.
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31
Oakland Corporation reported a net operating loss of $500,000 in 20X3 and elected to carry the loss forward to 20X4. Not included in the computation was a disallowed meals and entertainment expense of $20,000, tax-exempt income of $10,000, and deferred gain on a current year transaction treated as an installment sale of $250,000. The corporation's current earnings and profits for 20X3 would be:

A) ($260,000).
B) ($510,000).
C) ($720,000).
D) ($500,000).
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32
Battle Corporation redeems 20 percent of its stock for $100,000 in a stock redemption that is treated as an exchange by the shareholders. Battle's E&P at the date of theredemption is $200,000. Battle must reduce its earnings and profits by $100,000 because of the redemption.
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33
Which of the following statements best describes the priority of the tax treatment of a distribution from a corporation to a shareholder?

A) The distribution is a return of capital, then gain from sale of stock, and finally a dividend to the extent of the corporation's earnings and profits.
B) The distribution is a return of capital, then a dividend to the extent of the corporation's earnings and profits, and finally gain from sale of stock.
C) The shareholder can elect to treat the distribution as either a dividend to the extent of the corporation's earnings and profits or a return of capital, followed by gain from sale of stock.
D) The distribution is a dividend to the extent of the corporation's earnings and profits, then a return of capital, and finally gain from sale of stock.
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34
Madison Corporation reported taxable income of $400,000 in 20X3 and accrued federal income taxes of $136,000. Included in the computation of taxable income was regular depreciation of $200,000 (E&P depreciation is $60,000) and a net capital loss carryover of $20,000 from 20X2 utilized in 20X3. The corporation's current earnings and profits for 20X3 would be:

A) $380,000.
B) $424,000.
C) $404,000.
D) $344,000.
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35
Abbot Corporation reported a net operating loss of $400,000 in 20X3, which the corporation elected to carryforward to 20X4. Included in the computation of the loss was regular depreciation of $100,000 (E&P depreciation is $40,000), first year expensingunder §179 of $50,000, and a dividends received deduction of $10,000. The corporation's current earnings and profits for 20X3 would be:

A) ($290,000).
B) ($490,000).
C) ($330,000).
D) ($400,000).
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36
Which of these items is not an adjustment to taxable income or net loss to compute current E&P?

A) Net capital loss carryforward utilized in the current year from the prior year tax return.
B) Refund of prior year taxes for an accrual method taxpayer.
C) Dividends received deduction.
D) Tax-exempt income.
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37
A calendar-year corporation has negative current E&P of $500 and accumulated positive E&P of $1,000. The corporation makes a $600 distribution to its sole shareholder. Which of the following statements is true?

A) Up to $600 of the distribution could be a dividend depending on the balance in accumulated earnings and profits on the date of the distribution.
B) $0 of the distribution will be a dividend because current earnings and profits are negative.
C) $500 of the distribution will be a dividend because total earnings and profits is $500.
D) $600 of the distribution will be a dividend because accumulated earnings and profits is $1,000.
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38
The "family attribution" rules are automatically waived in a complete redemption of a shareholder's stock.
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39
Greenwich Corporation reported a net operating loss of $800,000 in 20X3, which the corporation elected to carryforward to 20X4. The computation of the loss did not include a disallowed fine of $50,000, life insurance proceeds of $500,000, and a current yearcharitable contribution of $10,000 that will be carried forward to 20X4. The corporation's current earnings and profits for 20X3 would be:

A) ($250,000).
B) ($360,000).
C) ($300,000).
D) ($260,000).
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40
A calendar-year corporation has positive current E&P of $500 and accumulated negative E&P of $1,200. The corporation makes a $400 distribution to its sole shareholder. Which of the following statements is true?

A) The distribution may be a dividend, depending on whether total earnings and profits at the date of the distribution is positive.
B) The distribution will be a dividend because current earnings and profits are positive and exceed the distribution.
C) The distribution will not be a dividend because total earnings and profits is a negative $700.
D) A distribution from a corporation to a shareholder is always a dividend, regardless of the balance in earnings and profits.
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41
Longhorn Company reports current E&P of $100,000 in 20X3 and accumulated E&P at the beginning of the year of negative $200,000. Longhorn distributed $300,000 to its sole shareholder on January 1, 20X3. The shareholder's tax basis in his stock in Longhorn is$100,000. How is the distribution treated by the shareholder in 20X3?

A) $300,000 dividend.
B) $0 dividend, $100,000 tax-free return of basis, and $200,000 capital gain.
C) $100,000 dividend and $200,000 tax-free return of basis.
D) $100,000 dividend, $100,000 tax-free return of basis, and $100,000 capital gain.
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42
Paladin Corporation had current and accumulated E&P of $500,000 at December 31,20X3. On December 31, the company made a distribution of land to its sole shareholder, Maria Mendez. The land's fair market value was $200,000 and its tax and E&P basis to Paladin was $250,000. Maria assumed a liability of $25,000 attached to the land. The tax consequences of the distribution to Paladin in 20X3 would be:

A) No loss recognized and a reduction in E&P of $225,000.
B) $50,000 loss recognized and a reduction in E&P of $200,000.
C) No loss recognized and a reduction in E&P of $200,000.
D) $50,000 loss recognized and a reduction in E&P of $225,000.
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43
Montclair Corporation had current and accumulated E&P of $500,000 at December 31,20X3. On December 31, the company made a distribution of land to its sole shareholder, Molly Pitcher. The land's fair market value was $200,000 and its tax and E&P basis to Montclair was $50,000. Molly assumed a liability of $25,000 attached to the land. The tax consequences of the distribution to Montclair in 20X3 would be:

A) No gain recognized and a reduction in E&P of $175,000.
B) $150,000 gain recognized and a reduction in E&P of $175,000.
C) No gain recognized and a reduction in E&P of $200,000.
D) $150,000 gain recognized and a reduction in E&P of $200,000.
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44
Which of the following payments could be treated as a constructive dividend by the IRS?

A) Interest paid to a shareholder/creditor.
B) End-of-year bonus payment to a shareholder/employee.
C) Rent paid to a shareholder/lessor.
D) All of these payments could be treated as a constructive dividend by the IRS
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45
Tar Heel Corporation had current and accumulated E&P of $500,000 at December 3120X3. On December 31, the company made a distribution of land to its sole shareholder, William Roy. The land's fair market value was $100,000 and its tax and E&P basis to Tar Heel was $25,000. William assumed a mortgage attached to the land of $10,000. The tax consequences of the distribution to William in 20X3 would be:

A) $100,000 dividend and a tax basis in the land of $90,000.
B) Dividend of $90,000 and a tax basis in the land of $90,000.
C) Dividend of $90,000 and a tax basis in the land of $100,000.
D) $100,000 dividend and a tax basis in the land of $100,000.
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46
Catamount Company had current and accumulated E&P of $500,000 at December 31,20X3. On December 31, the company made a distribution of land to its sole shareholder, Caroline West. The land's fair market value was $200,000 and its tax and E&P basis to Catamount was $250,000. The tax consequences of the distribution to Catamount in20X3 would be:

A) No loss recognized and a reduction in E&P of $250,000.
B) $50,000 loss recognized and a reduction in E&P of $150,000.
C) No loss recognized and a reduction in E&P of $200,000.
D) $50,000 loss recognized and a reduction in E&P of $250,000.
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47
Inca Company reports current E&P of negative $100,000 in 20X3 and accumulated E&P at the beginning of the year of $200,000. Inca distributed $300,000 to its sole shareholder on January 1, 20X3. How much of the distribution is treated as a dividend in 20X3?

A) $300,000.
B) $100,000.
C) $0.
D) $200,000.
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48
Which of the following statements is true?

A) A stock redemption not treated as an exchange will automatically be treated as a taxable dividend.
B) All stock redemptions are treated as exchanges for tax purposes.
C) All stock redemptions are treated as dividends if received by an individual.
D) A stock redemption is treated as an exchange only if it meets one of three stock ownership tests described in the Internal Revenue Code.
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49
Husker Corporation reports current E&P of negative $200,000 in 20X3 and accumulated E&P at the beginning of the year of $300,000. Husker distributed $200,000 to its sole shareholder on December 31, 20X3. The shareholder's tax basis in her stock in Husker is$50,000. How is the distribution treated by the shareholder in 20X3?

A) $100,000 dividend and $100,000 tax-free return of basis.
B) $200,000 dividend.
C) $0 dividend, $50,000 tax-free return of basis, and $150,000 capital gain.
D) $100,000 dividend, $50,000 tax-free return of basis, and $50,000 capital gain.
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50
Cavalier Corporation had current and accumulated E&P of $500,000 at December 3120X3. On December 31, the company made a distribution of land to its sole shareholder, Tom Jefferson. The land's fair market value was $200,000 and its tax and E&P basis to Cavalier was $50,000. The tax consequences of the distribution to Cavalier in 20X3 would be:

A) No gain recognized and a reduction in E&P of $200,000.
B) $150,000 gain recognized and a reduction in E&P of $50,000.
C) No gain recognized and a reduction in E&P of $50,000.
D) $150,000 gain recognized and a reduction in E&P of $200,000.
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51
Beaver Company reports current E&P of $100,000 in 20X3 and accumulated E&P at the beginning of the year of $200,000. Beaver distributed $400,000 to its sole shareholder on January 1, 20X3. The shareholder's tax basis in her stock in Beaver is $200,000. How is the distribution treated by the shareholder in 20X3?

A) $100,000 dividend, $200,000 tax-free return of basis, and $100,000 capital gain.
B) $200,000 dividend and $200,000 tax-free return of basis.
C) $300,000 dividend and $100,000 tax-free return of basis.
D) $400,000 dividend.
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52
Sara owns 60 percent of the stock of Lea Corporation. Unrelated individuals own theremaining 40 percent. For a stock redemption of Sara's stock to be treated as an exchange under the "substantially disproportionate" test, what percentage of Lea stock must Sara own after the redemption?

A) Any percentage less than 48 percent.
B) Any percentage less than 50 percent.
C) Any percentage less than 60 percent.
D) All stock redemptions involving individuals are treated as exchanges.
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53
Which of the following individuals is not considered "family" for purposes of applying the stock attribution rules to a stock redemption?

A) Grandparents.
B) Spouse.
C) Grandchildren.
D) Parents.
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54
Wildcat Corporation reports current E&P of negative $200,000 in 20X3 and accumulated E&P at the beginning of the year of $100,000. Wildcat distributed $300,000 to its sole shareholder on December 31, 20X3. How much of the distribution is treated as adividend in 20X3?

A) $0.
B) $300,000.
C) $100,000.
D) $200,000.
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55
Wonder Corporation declared a common stock dividend to all shareholders of record on September 30, 20X3. Shareholders will receive three shares of Wonder stock for each five shares of stock they already own. Diana owns 300 shares of Wonder stock with a tax basis of $90 per share (a total basis of $27,000). The fair market value of the Wonderstock was $180.00 per share on September 30, 20X3. What are the tax consequences of the stock dividend to Diana?

A) $10,800 dividend and a tax basis in the new stock of $180.00 per share.
B) $0 dividend income and a tax basis in the new stock of $56.25 per share.
C) $0 dividend income and a tax basis in the new stock of $67.50 per share.
D) $0 dividend income and a tax basis in the new stock of $180.00 per share.
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56
Sam owns 70 percent of the stock of Club Corporation. Unrelated individuals own theremaining 30 percent. For a stock redemption of Sam's stock to be treated as an exchange under the "substantially disproportionate" test, what percentage of Club stock must Sam own after the redemption?

A) Any percentage less than 50 percent.
B) Any percentage less than 56 percent.
C) Any percentage less than 70 percent.
D) All stock redemptions involving individuals are treated as exchanges.
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57
Which of the following stock dividends would be tax-free to the shareholder?

A) A 2-for-1 stock split to all holders of common stock.
B) A stock dividend to all holders of preferred stock.
C) A stock dividend where the shareholder could choose between cash and stock.
D) A 2-for-1 stock split to all holders of common stock and a stock dividend to all holders of preferred stock are tax-free to the shareholder.
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58
El Toro Corporation declared a common stock dividend to all shareholders of record on June 30, 20X3. Shareholders will receive 1 share of El Toro stock for each 2 shares of stock they already own. Raoul owns 300 shares of El Toro stock with a tax basis of $60 per share. The fair market value of the El Toro stock was $100 per share on June 30,20X3. What are the tax consequences of the stock dividend to Raoul?

A) $0 dividend income and a tax basis in the new stock of $60 per share.
B) $15,000 dividend and a tax basis in the new stock of $100 per share.
C) $0 dividend income and a tax basis in the new stock of $100 per share.
D) $0 dividend income and a tax basis in the new stock of $40 per share.
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59
Which of the following factors would not be considered in determining if compensation paid to a shareholder/employee is reasonable?

A) The individual's marginal income tax rate.
B) The individual's duties and responsibilities.
C) What individuals performing in comparable capacities at other companies are paid.
D) Whether the corporation has a formal compensation policy.
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60
Which of the following statements is not considered a potential answer to the question of why corporations pay dividends?

A) Paying dividends avoids the double taxation of corporate income.
B) Dividends are a signal to the capital markets about the health of a corporation's activities.
C) Paying dividends is a source of investor goodwill.
D) Demanding that managers pay out dividends restricts their investment activities and forces them to adopt more efficient investment policies.
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61
General Inertia Corporation made a pro rata distribution of $50,000 to Tiara, Inc. in partial liquidation of the company on December 31, 20X3. Tiara, Inc. owns 500 shares (50%) of General Inertia. The distribution was in exchange for 250 shares of Tiara's stock in the company. After the partial liquidation, Tiara continued to own 50% of the remaining stock in General Inertia. At the time of the distribution, the shares had a fair market value of $200 per share. Tiara's income tax basis in the shares was $100 per share. General Inertia had total E&P of $800,000 at the time of the distribution. What amount of dividend or capital gain does Tiara recognize because of the transaction?

A) Tiara recognizes dividend income of $50,000.
B) Tiara recognizes capital gain of $50,000.
C) Tiara does not recognize any dividend income or capital gain.
D) Tiara recognizes capital gain of $25,000.
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62
Viking Corporation is owned equally by Sven and his wife Olga, each of whom hold 100 shares in the company. Viking redeemed 75 shares of Sven's stock in the company on December 31, 20X3. Viking paid Sven $2,000 per share. His income tax basis in each share is $1,000. Viking has total E&P of $500,000. What are the tax consequences to Sven because of the stock redemption?

A) $75,000 capital gain and a tax basis in each of his remaining shares of $1,000.
B) $150,000 dividend and a tax basis in each of his remaining shares of $1,000.
C) $150,000 dividend and a tax basis in each of his remaining shares of $4,000.
D) $75,000 capital gain and a tax basis in each of his remaining shares of $2,000.
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63
St. Clair Company reports positive current E&P of $500,000 in 20X3 and positive accumulated E&P at the beginning of the year of $400,000. St. Clair Company distributed $600,000 to its sole shareholder, Danielle Brush on December 31, 20X3. Danielle's tax basis in her St. Clair stock is$120,000. How much of the $600,000 distribution is treated as a dividend to Danielle and what is her basis in St. Clair stock after the distribution?
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64
Panda Company is owned equally by Min, her husband Bin, her sister Xiao, and her grandson, Han, each of whom hold 100 shares in the company. Under the family attribution rules, how many shares of Panda stock is Min deemed to own?

A) 100.
B) 400.
C) 200.
D) 300.
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65
Viking Corporation is owned equally by Sven and his wife Olga, each of whom hold 100 shares in the company. Viking redeemed 75 shares of Sven's stock for $2,000 per share on December 31, 20X3. Viking has total E&P of $500,000. What are the taxconsequences to Viking because of the stock redemption?

A) A reduction of $187,500 in E&P because of the exchange.
B) A reduction of $375,000 in E&P because of the exchange.
C) No reduction in E&P because of the exchange.
D) A reduction of $150,000 in E&P because of the exchange.
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66
Comet Company is owned equally by Pat and his sister Pam, each of whom hold 100 shares in the company. Comet redeems 50 of Pam's shares on December 31, 20X3, for$1,000 per share in a transaction that Pam treats as an exchange for tax purposes. Comet has total E&P of $160,000 on December 31, 20X3. What are the tax consequences to Comet because of the stock redemption?

A) A reduction of $50,000 in E&P because of the exchange.
B) A reduction of $80,000 in E&P because of the exchange.
C) A reduction of $40,000 in E&P because of the exchange.
D) No reduction in E&P because of the exchange.
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67
Comet Company is owned equally by Pat and his sister Pam, each of whom hold 100 shares in the company. Comet redeems 50 of Pam's shares on December 31, 20X3, for$1,000 per share in a transaction that Pam treats as an exchange for tax purposes. Comet has total E&P of $250,000 on December 31, 20X3. What are the tax consequences to Comet because of the stock redemption?

A) No reduction in E&P because of the exchange.
B) A reduction of $125,000 in E&P because of the exchange.
C) A reduction of $62,500 in E&P because of the exchange.
D) A reduction of $50,000 in E&P because of the exchange.
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68
Beltway Company is owned equally by George, his brother Thomas, and a partnership owned 50 percent by George and his father Abe. Each of the three shareholders holds100 shares in the company. Under the §318 stock attribution rules, how many shares ofBeltway stock is George deemed to own?

A) 150.
B) 100.
C) 300.
D) 200.
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69
Tammy owns 100 shares in Star Struck Corporation. The other 100 shares are owned by her husband Tommy. Which of the following statements is true?

A) A stock redemption that completely terminates Tammy's direct interest in a corporation will be treated as a dividend for tax purposes.
B) A stock redemption that completely terminates Tammy's direct interest in a corporation will be treated as an exchange for tax purposes.
C) A stock redemption that completely terminates Tammy's direct interest in a corporation will be treated as a dividend to the extent that the redemption exceeds
Tammy's tax basis in the redeemed shares.
D) A stock redemption that completely terminates Tammy's direct interest in a corporation will be treated as an exchange if Tammy waives the family attribution rules and files a "triple i" agreement with the IRS.
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70
Austin Company reports positive current E&P of $200,000 and negative accumulated E&P of$300,000. Austin distributed $250,000 to its sole shareholder, Betsy Bevo, on December 31, 20X3. Betsy' tax basis in her stock is $125,000. How much of the $250,000 distribution is treated as a dividend to Betsy and what is her tax basis in Austin stock after the distribution?
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71
Comet Company is owned equally by Pat and his sister Pam, each of whom hold 100 shares in the company. Pam wants to reduce her ownership in the company, and it was decided that the company will redeem 50 of her shares for $1,000 per share on December31, 20X3. Pam's income tax basis in each share is $500. Comet has total E&P of$250,000. What are the tax consequences to Pam because of the stock redemption?

A) $50,000 dividend and a tax basis in each of her remaining shares of $100.
B) $25,000 capital gain and a tax basis in each of her remaining shares of $500.
C) $25,000 capital gain and a tax basis in each of her remaining shares of $100.
D) $50,000 dividend and a tax basis in each of her remaining shares of $50.
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72
Lansing Company is owned equally by Jennifer, her husband Dan, and DeWitt Corporation, which is owned 50 percent by Jennifer and her sister Jane. Each of the three shareholders holds 100 shares in the company. Under the §318 stock attribution rules, how many shares of Lansing stock is Jennifer deemed to own?

A) 100.
B) 250.
C) 200.
D) 300.
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73
Loon, Inc. reported taxable income of $600,000 in 20X3 and paid federal income taxes of $202,000.Not included in the company's computation of taxable income is tax-exempt interest of $30,000, disallowed meals and entertainment expenses of $15,000, and disallowed expenses related to the tax-exempt income of $4,000. Loon deducted depreciation of $200,000 on its tax return. Under the alternative (E&P) depreciation method, the deduction would have been $80,000. Compute the company's current E&P for 20X3.
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74
Superior Corporation reported taxable income of $1,000,000 in 20X3. Superior paid a dividend of$100,000 to its sole shareholder, Mary Yooper. Superior Corporation is subject to a flat rate tax of34%. The dividend meets the requirements to be a "qualified dividend" and Mary is subject to a tax rate of 15% on the dividend. What is the total federal income tax imposed on the corporate income earned by Superior including taxes on the amount distributed to Mary as a dividend?
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75
Corona Company is owned equally by Maria, her sister Carlita, her mother Gabriella, and her grandmother Olivia, each of whom hold 100 shares in the company. Under the family attribution rules, how many shares of Corona stock is Maria deemed to own?

A) 400.
B) 100.
C) 300.
D) 200.
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76
Erie Corporation reported taxable income of $2,200,000 in 20X3 before any deduction for anypayment to its sole shareholder and employee, LaBron Cleveland. Erie paid a bonus of $200,000 toLaBron at year-end. Erie Corporation is subject to a flat-rate tax of 34%. The bonus meets therequirements to be "reasonable" and is therefore deductible by Erie. LaBron is subject to a marginal tax rate of 35% on the bonus. What is the total federal income tax imposed on the corporate income earned by Erie and paid to LaBron as a bonus?
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77
Elk Company reports negative current E&P of $200,000 and positive accumulated E&P of$300,000. Elk distributed $200,000 to its sole shareholder, Barney Rubble, on December 31, 20X3. Barney's tax basis in his Elk stock is $75,000. What is the tax treatment of the distribution to Barney and what is his tax basis in Elk stock after the distribution?
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78
Houghton Company reports negative current E&P of ($500,000) and negative accumulated E&P of($800,000). Houghton distributed $100,000 to its sole shareholder, Blossom Applegate, on December 31, 20X3. Blossom's tax basis in her Houghton stock is $50,000. What is the tax treatment of the distribution to Blossom and what is her tax basis in Houghton stock after the distribution?
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79
Lansing Company is owned equally by Jennifer, her husband Dan, and DeWitt Corporation, which is owned 50 percent by Jennifer and her sister Jane. Each of the three shareholders holds 100 shares in the company. Under the §318 stock attribution rules, how many shares of Lansing stock is DeWitt Corporation deemed to own?

A) 200.
B) 300.
C) 100.
D) 250.
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80
General Inertia Corporation made a distribution of $50,000 to Henry Tiara in partial liquidation of the company on December 31, 20X3. Henry owns 500 shares (50%) of General Inertia. The distribution was in exchange for 250 shares of Henry's stock in the company. After the partial liquidation, Henry continued to own 50% of the remainingstock in General Inertia. At the time of the distribution, the shares had a fair market value of $200 per share. Henry's income tax basis in the shares was $100 per share. GeneralInertia had total E&P of $800,000 at the time of the distribution. What are the taxconsequences to Henry because of the transaction?

A) Henry has dividend income of $50,000 and a tax basis in his remaining shares of $200 per share.
B) Henry has capital gain of $25,000 and a tax basis in his remaining shares of $200 per share.
C) Henry has capital gain of $25,000 and a tax basis in his remaining shares of $100 per share.
D) Henry has dividend income of $50,000 and a tax basis in his remaining shares of $100 per share.
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