Tiger Corporation, a Privately-Held Company, Has One Class of Voting

Short Answer

Tiger Corporation, a privately-held company, has one class of voting common stock, of which 1,000 shares are issued and outstanding. The shares are owned as follows: $$\begin{array} { | l | r | r | r | } \hline & \text { FMV } & \text { Tax Basis } & \text { Appreciation } \\\hline \text { Cash } & \$ 400,000 & \$ 400,000 & \\\hline \text { Building } & 100,000 & 20,000 & 80,000 \\\hline \text { Land } & \underline { 300,000 } & \underline { 180,000 } & 120,000 \\\hline \text { Total } & \$ 800,000 & \$ 600,000 & \$ 200,000 \\\hline\end{array}$$ How many shares of stock is Mark deemed to own under the family attribution rules in a stock redemption?