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Corporate Taxation, Taxation

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A owns all of the stock of X. The stock’s basis is $2,300. X has a total of current earnings and profits of $1,500 but accumulated earnings and profits of negative $500 (i.e., an accumulated deficit).

a) X distributes $1,200 cash to A “with respect to his stock” (i.e., as a state law “dividend”). How is the $1,200 distribution treated for tax purposes? (4 pts.)

b) Alternatively, X distributes $4,000 cash to A “with respect to his stock” (i.e., as a state law “dividend”). How is the $4,000 distribution treated for tax purposes? (4 pts.)

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