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Ethel, Hannah, and Samuel, unrelated individuals, own the stock in Broadbill Corporation (E & P of $700,000) as follows: Ethel, 300 shares; Hannah, 300 shares; and Samuel, 400 shares. Broadbill redeems 200 of Samuel's shares (basis of $175,000) for $250,000. If Samuel's stock is a capital asset and has been held for over three years, Samuel has:


A) A long-term capital gain of $75,000.
B) A short-term capital gain of $75,000.
C) Ordinary income of $250,000.
D) Ordinary income of $75,000.
E) None of these.

F) C) and E)
G) A) and E)

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Timothy owns 100% of Forsythia Corporation's stock. Corporate employees and annual salaries include Timothy ($300,000); Richard, Timothy's son ($80,000); Rita, Timothy's daughter ($100,000); and Sandy ($120,000). The operation of Forsythia Corporation is shared about equally between Timothy and Sandy (an unrelated party). Richard and Rita are full-time college students at a university about 150 miles away. Forsythia Corporation has substantial E & P but has not distributed a dividend for the past five years. Discuss problems related to the salary arrangement for Forsythia Corporation.

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The salaries paid to Richard and Rita ar...

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Tanya is in the 32% tax bracket. She acquired 1,000 shares of stock in Swan Corporation seven years ago for $100 a share. In the current year, Swan Corporation (E & P of $1.2 million) redeems all of Tanya's shares for $160,000. What are the income tax consequences to Tanya if: a. The redemption qualifies for sale or exchange treatment and Tanya has no other transactions in the current year involving capital assets? b. The redemption does not qualify for sale or exchange treatment?

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Her income tax liability on the $60,000 ...

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Dividends taxed as ordinary income are considered investment income for purposes of the investment interest expense limitation.

A) True
B) False

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When current E & P has a deficit and accumulated E & P is positive, the two accounts are netted at the date of the distribution. If a positive balance results, the distribution is a dividend to the extent of the balance.

A) True
B) False

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Using the legend provided, classify each statement accordingly. In All cases, assume that taxable income is being adjusted to arrive at current E & P for 2019. -Intangible drilling costs deducted currently.


A) Increase
B) Decrease
C) No effect

D) All of the above
E) A) and B)

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The terms "earnings and profits" and "retained earnings" are identical in meaning.

A) True
B) False

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Matching Using the legend provided, classify each statement accordingly. In all cases, assume that taxable income is being adjusted to arrive at current E & P for 2019. -Gain on installment sale in 2019 deferred until 2020.


A) Increase
B) Decrease
C) No effect

D) B) and C)
E) A) and C)

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Maria owns 75% and Christopher owns 25% of Cockatoo Corporation, a calendar year taxpayer. Cockatoo makes a $600,000 distribution to Maria on April 1 and a $200,000 distribution to Christopher on May 1. Cockatoo's current E & P is $120,000 and its accumulated E & P is $500,000. What are the tax implications of the distributions to Maria and Christopher?

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Current E & P is allocated on a pro rata...

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In general, if a shareholder's ownership interest is not diminished as a result of a stock redemption, the Code will treat the transaction as a sale or exchange.

A) True
B) False

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All cash distributions received from a corporation with a positive balance in accumulated E & P at the beginning of the year will be taxed as dividend income.

A) True
B) False

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When computing E & P, taxable income is not adjusted for § 179 expense.

A) True
B) False

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Gold Corporation has accumulated E & P of $2 million as of January 1 of the current year. During the year, it expects to have earnings from operations of $1,680,000 and to distribute $900,000 in cash to shareholders. Gold Corporation also expects to sell an asset for a loss of $2 million. Thus, it anticipates incurring a deficit of $320,000 for the year. What can Gold do to minimize the amount of dividend income to its shareholders?

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Gold should recognize the loss as soon a...

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Coffee Corporation has 2,000 shares of common stock outstanding. John owns 700 of the shares, John's grandfather owns 100 shares, John's father owns 100 shares, John's ex-wife owns 700 shares, and Redbird Partnership owns 400 shares. John is a 50% partner in Redbird Partnership. How many shares is he deemed to own in Coffee Corporation under the § 318 attribution rules?


A) 700
B) 1,000
C) 1,100
D) 1,700
E) None of these.

F) A) and D)
G) B) and C)

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Jen, the sole shareholder of Mahogany Corporation, sold her stock to Jason on July 1 for $90,000. Jen's stock basis at the beginning of the year was $60,000. Mahogany made a $30,000 cash distribution to Jen immediately before the sale, and Jason received a $60,000 cash distribution from Mahogany on November 1. As of the beginning of the current year, Mahogany had $16,000 in accumulated E & P, and current E & P (before distributions) is $30,000. What are the tax consequences of these transactions to Jen and Jason?

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The $30,000 in current E & P is allocate...

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Scarlet Corporation is an accrual basis, calendar year corporation. Scarlet distributes inventory (basis of $20,000; fair market value of $40,000) to Frank, its shareholder. Assuming that Scarlet has $500,000 of current E & P, what is the impact of the distribution on Scarlet Corporation and on Frank?

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Scarlet's E & P is increased by the $20,...

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In June of the current year, Marigold Corporation declares a $4 dividend out of E & P on each share of common stock to shareholders of record on August 1. Ellen and Tim each purchase 100 shares of Marigold stock on July 1. On July 15, Ellen also purchases a short position in Marigold. Tim sells 50 of his shares on August 10 and continues to hold the remaining 50 shares through the end of the year. Ellen closes her short position in Marigold on October 15. With respect to the dividends, which of the following is correct?


A) Ellen will have $400 of qualifying dividends subject to reduced tax rates and $400 of ordinary income (from dividends paid on the short position of Marigold stock) .
B) Tim will have $200 of qualifying dividends subject to reduced tax rates and $200 of ordinary income.
C) All $800 of Ellen's dividends will qualify for reduced tax rates.
D) All $400 of Tim's dividends will qualify for reduced tax rates.
E) None of these.

F) B) and D)
G) A) and B)

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Which one of the following statements is false?


A) Most countries that trade with the United States do not impose a double tax on dividends.
B) Tax proposals that include corporate integration would eliminate the double tax on dividends.
C) The double tax on dividends may make corporations more financially vulnerable during economic downturns.
D) Many of the arguments in support of the double tax on dividends relate to fairness.
E) None of these.

F) B) and E)
G) B) and C)

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Ten years ago, Carrie purchased 2,000 shares of common stock in Osprey Corporation for $20,000. In the current year, Carrie receives a nontaxable stock dividend of 20 shares of Osprey preferred. Values at the time of the dividend are $8,000 for the preferred stock and $72,000 for the common. Based on this information, Carrie's basis in the stock is:


A) $20,000 in the common and $8,000 in the preferred.
B) $2,000 in the common and $18,000 in the preferred.
C) $18,000 in the common and $2,000 in the preferred.
D) $19,802 in the common and $198 in the preferred.
E) None of these.

F) B) and D)
G) C) and D)

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Using the legend provided, classify each statement accordingly. In All cases, assume that taxable income is being adjusted to arrive at current E & P for 2019. -Gain realized (but not recognized) on a like-kind exchange.


A) Increase
B) Decrease
C) No effect

D) All of the above
E) B) and C)

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