McGraw-Hill's Taxation of Individuals and Business Entities 3rd Edition by Brian Spilker, Benjamin Ayers, John Robinson, Edmund Outslay, Ronald Worsham, John Barrick, Connie Weaver

Exercise 4

The Limited Brands recently repurchased 68,965,000 of its shares, paying $29 per share.The total number of shares outstanding before the redemption was 473,223,066.The total number of shares outstanding after the redemption was 404,258,066.Assume your client owned 20,000 shares of stock in The Limited.What is the minimum number of shares she must tender to receive exchange treatment under the "substantially disproportionate with respect to the shareholder" change-in-ownership rules?