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(a) Addition to each shareholder's stock basis   67

(b) Addition to each shareholder's AAA            17

Detailed computations are required to answer each question.

The stock of X is owned equally by two shareholders: Y (an individual with a stock basis of $100) and A (an individual with a stock basis of $40). X uses the accrual method, A and Y use the cash method, and all use the calendar year. (Assume 1059 does not apply.) During the current year, X accrued income and expense as set follows. X has always been an S corporation.

Gross income from business                                        $500

Dividends on AT&T stock (consider section 243)              100

Interest on municipal bonds (section 103)                       100

Capital gain                                                               100

Total:                                                                      $800

Deductible section 162(a)(1) business expenses               $430

Noncapital expenses not deductible under section 162(e)     90

Capital losses (see section 1211(a))                                146

Total                                                                        $666

Net                                                                          $134

(a) What is X's E&P?

(b) How much is each shareholder's personal income tax return affected for the current year by the tax items of X? (Show any S level taxes, separately computed income items for each shareholder, and nonseparately computed income for each shareholder.)

(c) How will X's distribution of $100 to each shareholder in the current year affect the shareholders? (Show a complete calculation of basis and the effect of the distributionfor each shareholder.)

(d) Alternatively, X has E&P of $100 from years before it was an S corporation and nothing in its AAA from prior S years. The $100 is capital gain from the sale of stock held for investment and the $500 gross income from business is also gross receipts from business. Assume the stock for investment was acquired while an S corporation. Assume other facts remaining the same including the $100 distribution to each shareholder. Discuss the following, showing calculations where appropriate.

(1) 1374 tax,

(2) 1375 tax (calculate excess passive income) and consequences, and

(3) AAA and E&P and basis.

Taxation, Accounting

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