determine the tax treatment of distribution (dividends, return of capital, or capital gain) for the shareholders. (assume each shareholder has adequate basis in the corporation).

SWFT Comprehensive Volume 2019
42nd Edition
ISBN:9780357233306
Author:Maloney
Publisher:Maloney
Chapter19: Corporations: Distributions Not In Complete Liquidation
Section: Chapter Questions
Problem 35P
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PART 1: Fallout Corporation (a calendar year, accrual basis taxpayer) had the following transactions in 2022:
Taxable Income $195, 000 Federal Income Tax Liability Paid 45,000 Tax - Exempt Interest Income 5,000
Excess of Capital Loss over Capital Gains 1,000 Section 179 Expense elected in 2022 15,000 Dividends
Received from Domestic Corporation (less than 20% owned) 40,000 MACRS Depreciation deduction 18,000
Straight-line depreciation using ADS class lives 10,000 Compute E & P for tax year 2022 and go to Part 2
PART 2: On December 31st, Fallout Corporation makes a total distribution of $200,000 to it's two
shareholders, who each own 50% of the corporation. At the beginning of the current year, the corporation
has a deficit in accumulated E&P of $(23,000). Using the figure for current E&P that you calculated in part 1,
determine the tax treatment of distribution (dividends, return of capital, or capital gain) for the shareholders.
(assume each shareholder has adequate basis in the corporation).
Transcribed Image Text:PART 1: Fallout Corporation (a calendar year, accrual basis taxpayer) had the following transactions in 2022: Taxable Income $195, 000 Federal Income Tax Liability Paid 45,000 Tax - Exempt Interest Income 5,000 Excess of Capital Loss over Capital Gains 1,000 Section 179 Expense elected in 2022 15,000 Dividends Received from Domestic Corporation (less than 20% owned) 40,000 MACRS Depreciation deduction 18,000 Straight-line depreciation using ADS class lives 10,000 Compute E & P for tax year 2022 and go to Part 2 PART 2: On December 31st, Fallout Corporation makes a total distribution of $200,000 to it's two shareholders, who each own 50% of the corporation. At the beginning of the current year, the corporation has a deficit in accumulated E&P of $(23,000). Using the figure for current E&P that you calculated in part 1, determine the tax treatment of distribution (dividends, return of capital, or capital gain) for the shareholders. (assume each shareholder has adequate basis in the corporation).
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