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

Short Answer

Geneva Corporation, a privately-held company, has one class of voting common stock, of which 1,000 shares are issued and outstanding. Madison has a 20 percent interest in the partnership. The remaining 80 percent is owned by unrelated individuals. Madison owns 40% of Packer Corporation. The other 60 percent is owned by her father. The shares are owned as follows: $$\begin{array} { | l | r | } \hline \text { Corporate tax: } \$ 1,000,000 \times & \$ 340,000 \\34 \% & \\\hline \text { Shareholder tax: } \$ 100,000 & 15,000 \\\times 15 \% &\\ \text { Total income tax } & \$ 355,000 \\\hline\end{array}$$ How many shares of stock is Madison deemed to own under the family attribution rules in a stock redemption?