C and D organized Z Corporation 10 years ago, each contributing $40,000 and each receiving 400 shares of common stock. Five years ago, in June, Z declared a one for one dividend payable in pure preferred with a $400 fair market value. The value of the common stock after the distribution was $1,600 per share. In that year, five years ago, Z had accumulated E&P of $52,000 and current E&P of $12,000. In the current year, Z has accumulated E&P of $112,000 and current E&P of $8,000. In December of the current year, C sells all of his preferred stock to E for $36,000. In June of that same year, C had previously sold all of his common stock to F for $200,000. E is C’s son. Same facts as Question 7, except in the current year Z redeems all of C’s preferred stock in exchange for $36,000.   a. 306 does not apply to this transaction. The entire $36,000 is ordinary income.   b. 306 does not apply to this transaction. Of the redemption proceeds, $32,000 is ordinary income.   c. 306 does not apply because of the complete termination of the preferred stock interest.   d. None of the above.

SWFT Corp Partner Estates Trusts
42nd Edition
ISBN:9780357161548
Author:Raabe
Publisher:Raabe
Chapter7: Corporations: Reorganizations
Section: Chapter Questions
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C and D organized Z Corporation 10 years ago, each contributing $40,000 and each receiving 400 shares of common stock. Five years ago, in June, Z declared a one for one dividend payable in pure preferred with a $400 fair market value. The value of the common stock after the distribution was $1,600 per share. In that year, five years ago, Z had accumulated E&P of $52,000 and current E&P of $12,000. In the current year, Z has accumulated E&P of $112,000 and current E&P of $8,000. In December of the current year, C sells all of his preferred stock to E for $36,000. In June of that same year, C had previously sold all of his common stock to F for $200,000. E is C’s son.

Same facts as Question 7, except in the current year Z redeems all of C’s preferred stock in exchange for $36,000.

  a.

306 does not apply to this transaction. The entire $36,000 is ordinary income.

  b.

306 does not apply to this transaction. Of the redemption proceeds, $32,000 is ordinary income.

  c.

306 does not apply because of the complete termination of the preferred stock interest.

  d.

None of the above.

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