Question: During the current year, Zeta Corporation

> In the current year, Burbank Corporation incurs an AMT for the first time. Its AMT is due to an ACE adjustment resulting from Burbank’s receiving $4 million of life insurance proceeds upon the death of the corporation’s chief executive officer. The polic

> Discuss the regular tax and AMT depreciation rules applicable to the following types of property acquired in the current year. a. Section 1250 property—a factory building b. Section 1245 property—a drill press

> Why might shareholders avoid Sec. 351 treatment? Explain three ways they can accomplish this end.

> Indicate whether the following items are includible in regular taxable income, preadjustment AMTI, and/or ACE. Also indicate whether a corporation must make a positive, negative, or zero adjustment when calculating preadjustment AMTI and when calculating

> Some tax scholars say tax-exempt interest on state or local bonds that are not private activity bonds can, because of the ACE adjustment, produce three different effective tax rates depending on the corporation’s tax situation: (1) a 0% effective tax rat

> Florida Corporation incurs AMT for the first time in the current year. The main reason for incurring the AMT is a $2 million gain on a current year installment sale that Florida is recognizing over ten years for regular tax purposes. Explain to Florida’s

> What adjustment does a corporation make if ACE is more than preadjustment AMTI? If ACE is less than preadjustment AMTI?

> Identify each of the following as a tax preference item (PREF), an AMT adjustment item to calculate preadjustment AMTI (ADJ), an item to adjust from preadjustment AMTI to ACE (ACE), or none of these (NONE): a. Percentage depletion in excess of a propert

> Determine whether the following statements relating to the AMT for a corporation are true or false. If false, explain why. a. Tax preference items only increase AMTI. b. A corporation uses the same NOL carryover amount for regular tax and AMT purposes.

> Menifee Corporation has conducted business for several years, and its annual gross receipts never have been more than $4 million. Jackie, who has owned all of Menifee’s stock since she incorporated it, purchases all of Estill Corporation’s stock in the c

> Agnew Corporation operates a small manufacturing business. During Year 1 (its first tax year, which is 12 months long), Agnew sells goods for $3.8 million for which the cost of goods sold is $2.8 million. Agnew’s owner estimates that future sales and cos

> What special rules (if any) apply to the AMT calculation for the following entities: a. Corporations, particularly small ones b. Controlled groups c. S corporations

> Dunn Corporation is not a small corporation exempt from the AMT. Dunn’s CPA does not calculate the AMT because he knows that Dunn’s taxable income is less than the $40,000 AMT exemption amount allowed to corporations. Is the CPA correct in his belief? Ex

> What are the advantages of business bad debt treatment when a shareholder’s loan or advance to a corporation cannot be repaid? What must the debtholder show to claim a business bad debt deduction?

> Define the following terms relating to the AMT: a. Tax preference item b. AMT adjustment item c. Adjusted current earnings d. Alternative minimum taxable income e. AMT exemption amount f. Tentative minimum tax g. Minimum tax credit

> For each of the following statements, indicate whether the statement is true for the PHC tax only, the accumulated earnings tax only, both taxes, or neither tax. a. The tax is imposed only if the corporation satisfies certain stock ownership and income

> Explain Congress’ intent for enacting the AMT.

> Stock in Random Corporation is owned equally by two individual shareholders. During the current year, Random reports the following results: Income: Rentals………………………………………………………………$200,000 Dividend (from a 25%-owned domestic corporation)…………….30,000 Taxa

> Eagle Corporation operates a family business established by Edward Eagle, Sr. ten years ago. Edward Eagle, Sr. died, and the Eagle stock passed to his children. The corporation operates rental property and also invests in dividend paying stock and corpor

> Goss Corporation is a leading manufacturer of hangers for the laundry and dry cleaning industry. The family-owned business has prospered for many years and has generated approximately $100 million of sales and $8 million in after-tax profits. Your accoun

> John owns all 100 shares of stock in Jamaica Corporation, which has $100,000 of current E&P. John would like to receive a $50,000 distribution from the corporation. Jamaica owns several assets that it could distribute to John. What are the tax consequenc

> Fifteen years ago, husband and wife Stuart and Marsha Widell organized Widell Engineering Associates (WEA), a Delaware corporation that builds, repairs, and manages waste treatment plants throughout the Southwest. The Widells capitalized WEA with cash of

> Sara owns 60% of Mayfield Corporation’s single class of stock. A group of five family members and three key employees own the remaining 40%. Mayfield is a calendar year taxpayer that uses the accrual method of accounting. Sara is a Mayfield officer and d

> John and Jean own 80% and 20%, respectively, of Plum Corporation stock. Thanks to their hard work, Plum’s software sales have sky rocketed. In its first year of operation Plum’s earnings were minimal, but four years later, Plum grossed $10 million. Plum

> What are the advantages of Sec. 1244 loss treatment when a stock investment becomes worthless? What conditions must be met to qualify for this treatment?

> Bruce and Bob organize Black LLC on May 10 of the current year. What is the entity’s default tax classification? Are any alternative classification(s) available? If so, (1) how do Bruce and Bob elect the alternative classification(s) and (2) what are the

> Scott and Lynn Brown each own 50% of Benson Corporation stock. During the current year, Benson made the following distributions to its shareholders: Benson had E&P of $250,000 immediately before the distributions. Prepare a memorandum for your tax m

> When the IRS audited Winter Corporation’s current year tax return, the IRS disallowed $10,000 of travel and entertainment expenses incurred by Charles, an officer-shareholder, because of inadequate documentation. The IRS asserted that the $10,000 expendi

> Jane owns 150 of the 200 outstanding shares of Parent Corporation stock. Parent owns 160 of the 200 outstanding shares of Subsidiary Corporation stock. Jane sells 50 shares of her Parent stock to Subsidiary for $40,000. Jane’s basis in her Parent shares

> Bob owns 60 of the 100 outstanding shares of Dazzle Corporation stock and 80 of the 100 outstanding shares of Razzle Corporation stock. Bob’s basis in his Dazzle shares is $12,000, and his basis in his Razzle shares is $8,000. Bob sells 30 of his Dazzle

> Fran owns all 100 shares of Star Corporation stock. Her stock basis is $60,000. On December 1 of the current year, Star distributes 50 shares of preferred stock to Fran in a nontaxable distribution. In the year of the distribution, Star’s total E&P is $1

> Bailey is one of four equal unrelated shareholders of Checker Corporation. Bailey has held Checker stock for four years and has a basis in her stock of $40,000. Checker has $280,000 of current and accumulated E&P and distributes $100,000 to Bailey. a. W

> Alice, Bob, Carol, the ABC Partnership, Franklin Corporation, and the Gleason Family Trust own shares of Holston Corporation’s single class of stock as follows: The Holston shareholders have owned their shares for more than one year. T

> Andrew, Bea, Carl, and Carl, Jr. (Carl’s son), and Tetra Corporation own all of the single class of Excel Corporation stock as follows: Andrew, Bea, and Carl are unrelated. Bea owns 75% of the Tetra stock, and Andrew owns the remaining

> Alan, Barbara, and Dave are unrelated. Each has owned 100 shares of Time Corporation stock for five years and each has a $60,000 basis in those shares. Time’s E&P is $240,000. Time redeems all 100 of Alan’s shares for their $100,000 FMV. a. What are the

> White Corporation has 100 shares of stock outstanding. Ann owns 40 of these shares, and unrelated individuals own the remaining 60 shares. White redeems 30 of Ann’s shares for $30,000. In the year of the redemption, White has $30,000 of paid-in capital a

> What are the advantages and disadvantages of using debt in a firm’s capital structure?

> John died on March 3, 2017. His gross estate of $8.25 million includes First Corporation stock (400 of the 1,000 outstanding shares) worth $5 million or $12,500 per share ($5,000,000/400). This FMV amount also is the estate’s basis in the stock (see Chap

> Unrelated parties Amy, Beth, Carla, and Delta Corporation each own 25 of the 100 outstanding shares of Axle Corporation stock. In a transaction that qualifies as a partial liquidation, Axle distributes $20,000 cash to each shareholder in exchange for fiv

> Of the 9,500 shares of Favor Corporation stock outstanding, Olsen owns 6,100 shares. Unrelated parties own the remaining shares. To bolster its stock price, Favor plans to reduce the total number of shares outstanding by redeeming some of the shares held

> Four unrelated shareholders own Benton Corporation’s 400 shares of outstanding stock. As indicated below, Benton redeems a total of 100 shares for $500 per share from three of its shareholders. Each shareholder has a $230 per share basi

> Paul owns all 100 shares of Presto Corporation stock. His basis in the stock is $10,000. Presto has $100,000 of E&P. Presto redeems 25 of Paul’s shares for $30,000. What are the tax consequences of the redemption to Paul and to Presto?

> Moose Corporation’s 400 shares of outstanding stock are owned as follows: Name ……………….……………….……………….…… Shares Lara (an individual) ……………….………………….….………60 LMN Partnership (Lara is a 20% partner)………………..50 LST Partnership (Lara is a 70% partner).……

> Trusty Corporation has a single class of common stock outstanding. Jim owns 200 shares, which he purchased for $50 per share two years ago. On April 10 of the current year, Trusty distributes to its common shareholders one right to purchase for $60 one c

> Moss Corporation has a single class of common stock outstanding. Tillie owns 1,000 shares, which she purchased five years ago for $100,000. Moss declares a stock dividend payable in 8% preferred stock having a $100 par value. Each shareholder receives on

> Wilton Corporation has a single class of common stock outstanding. Robert owns 100 shares, which he purchased six years ago for $100,000. In the current year, when the stock is worth $1,200 per share, Wilton declares a 10% dividend payable in common stoc

> Forward Corporation is owned by a group of 15 shareholders. During the current year, Forward pays $550,000 in salary and bonuses to Alvin, its president and controlling shareholder. The corporation’s marginal tax rate is 34%, and Alvin’s marginal tax rat

> What factors did Congress mandate to be considered in determining whether indebtedness is classified as debt or equity for tax purposes?

> King Corporation is a profitable manufacturing concern with $800,000 of E&P. It is owned in equal shares by Harry and Wilma, husband and wife. Both individuals are actively involved in the business. Determine the tax consequences of the following indepen

> On May 15 of the current year, Quick Corporation distributes to its shareholder Calvin a building having a $250,000 FMV and used in Quick’s business. The building originally cost $180,000. Quick claimed $30,000 of straight-line depreciation, so that the

> On May 10 of the current year, Stowe Corporation distributes to its shareholder Arlene $20,000 in cash and land (a capital asset) having a $50,000 FMV. The land has a $15,000 adjusted basis (for both taxable income and E&P purposes) and is subject to a $

> In the current year, Sedgwick Corporation has $100,000 of current and accumulated E&P. On March 3, Sedgwick distributes to its shareholder Dina a parcel of land (a capital asset) having a $56,000 FMV. The land has a $40,000 adjusted basis (for both taxab

> At the beginning of the current (non-leap) year, Charles owns all of Pearl Corporation’s outstanding stock. His basis in the stock is $80,000. On July 1, he sells all his stock to Donald for $125,000. During the year, Pearl, a calendar year taxpayer, mak

> Pink Corporation is a calendar year taxpayer. Pete owns one-third (100 shares) of Pink stock. His basis in the stock is $25,000. Cheryl owns two-thirds (200 shares) of Pink stock. Her basis in the stock is $40,000. On June 10 of the current year, Pink di

> Clover Corporation is a calendar year taxpayer. Connie owns all of its stock. Her basis in the stock is $10,000. On April 1 of the current (non-leap) year Clover distributes $52,000 to Connie. Determine the tax consequences of the cash distribution in ea

> Investors formed Peach Corporation in Year 1. Its current E&P (or current E&P deficit) and distributions for Years 1 through 4 are as follows: What is Peach’s accumulated E&P at the beginning of Years 1 through 4? Curre

> Water Corporation reports $500,000 of taxable income for the current year. The following additional information is available: • For the current year, Water reports an $80,000 long-term capital loss and no capital gains. • Taxable income includes $80,0

> How does the assignment of income doctrine apply to a Sec. 351 exchange?

> Beach Corporation, an accrual basis taxpayer, reports the following results for the current year: a. What is Beach’s taxable income? b. What is Beach’s current E&P? Income: Gross profit from manufacturing ope

> Alabre Corporation has 150,000 shares of common stock outstanding and pays quarterly dividends of $0.15 per share. At the beginning of the current year, the balance in its accumulated E&P account is $23,000. Alabre would like to have sufficient E&P to pa

> Jana owns all 100 shares of Stone Corporation stock having a $1 million FMV. Her basis in the stock is $400,000. Stone’s E&P balance is $600,000. Michael would like to purchase the stock but wants only the corporation’s non-cash assets valued at $750,000

> George owns 100 of the 1,000 outstanding shares of Polar Corporation common stock. Under the Sec. 318 family attribution rules, to which of the following individuals will ownership of George’s stock be attributed? In other words, who is deemed to constru

> Marsha receives a $10,000 cash distribution from Dye Corporation in April of the current year. At the beginning of the year, Dye has $4,000 of accumulated E&P and $8,000 of current E&P. Dye also distributed $10,000 in cash to Barbara, who purchased all 2

> George owns all 100 shares of Gumby’s Pizza Corporation. The shares are worth $200,000, while George’s basis is only $70,000. Mary and George have reached a tentative agreement under which George will sell all his shares to Mary. However, Mary is unwilli

> Price Corporation has 100 shares of common stock outstanding. Price repurchased all of Penny’s 30 shares for $35,000 cash during the current year. Three years ago, Penny received the shares as a gift from her mother. Her basis in the shares is $16,000. P

> Neil purchased land from Spring Harbor, his 100%-owned corporation, for $275,000. The corporation purchased the land three years ago for $300,000. Similar tracts of land located nearby have sold for $400,000 in recent months. What tax issues should be co

> Why are stock dividends generally nontaxable? Under what circumstances are stock dividends taxable?

> What is a constructive dividend? Under what circumstances is the IRS likely to argue that a constructive dividend has been paid?

> Mark transfers all the property of his sole proprietorship to newly formed Utah Corporation in exchange for all the Utah stock. Mark has claimed depreciation on some of the property. Under what circumstances is Mark required to recapture previously claim

> Walnut Corporation owns a building with a $120,000 adjusted basis and a $160,000 FMV. Walnut’s E&P is $200,000. Should the corporation sell the building and distribute the sales proceeds to its shareholders or distribute the building to its shareholders

> Hickory Corporation owns a building with a $160,000 adjusted basis and a $120,000 FMV. Hickory’s E&P is $200,000. Should the corporation sell the building and distribute the sales proceeds to its shareholders or distribute the property to its shareholder

> Does the timing of a distribution matter as to whether it is taxed as a dividend or treated as a return of capital? Explain.

> Badger Corporation was incorporated in the current year. It reports an $8,000 NOL on its initial tax return. Badger distributes $2,500 to its shareholders. Is it possible for this distribution to be taxed as a dividend to Badger’s shareholders? Explain.

> What effect do the following transactions have on the calculation of Young Corporation’s current E&P? Assume that the starting point for the calculation is Young’s taxable income for the current year. a. The corporation earns tax-exempt interest income

> Pecan Corporation distributes land to a noncorporate shareholder. Explain how the following items are determined: a. The amount of the distribution b. The amount of the dividend c. The shareholder’s basis in the land d. When the holding period for th

> Describe the effect of a $100,000 cash distribution paid on January 1 to the sole shareholder of a calendar year corporation whose stock basis is $25,000 when the corporation has a. $100,000 of current E&P and $100,000 of accumulated E&P b. A $50,000 a

> Why is it necessary to distinguish between current and accumulated E&P?

> Explain how a corporation computes its current and accumulated E&P balances.

> What is a bootstrap acquisition? What are the tax consequences of such a transaction?

> What factor(s) would the IRS likely consider to determine whether the transfer of a liability to a corporation in a Sec. 351 exchange was motivated by a business purpose?

> Explain the tax consequences, to both the corporation and a shareholder-employee, of an IRS determination that a portion of the compensation paid in a prior tax year is unreasonable. What steps can the corporation and shareholder- employee take to avoid

> What is a preferred stock bailout? How does Sec. 306 operate to prevent a shareholder from realizing the otherwise available tax benefits of a preferred stock bailout?

> Under what circumstances does a corporation recognize gain or loss when it distributes noncash property in redemption of its stock? What effect does a redemption distribution have on the distributing corporation’s E&P?

> Why does a redemption that qualifies for sale treatment under Sec. 303 usually result in the shareholder’s recognizing little or no gain or loss?

> Abel, the sole shareholder of Ace Corporation, has an opportunity to purchase the assets of a sole proprietorship for $50,000 in cash. Ace has a substantial E&P balance. Abel does not have sufficient cash to personally make the purchase. If Abel obtains

> Explain the purpose of the attribution rules in determining stock ownership in a redemption. Describe the four types of attribution rules that apply to redemptions.

> What conditions must be met for a redemption to be treated as a sale by the redeeming shareholder?

> Field Corporation redeems 100 shares of its stock from Andrew for $10,000. Andrew’s basis in the shares is $8,000. Explain possible alternative tax treatments of Andrew’s receiving the $10,000.

> What is a stock redemption? What are some reasons for redeeming stock? Why are some redemptions treated as sales and others as dividends?

> Several years ago, Brian formed Sigma Corporation, a retail company ineligible for the U.S. production activities deduction. Sigma uses the accrual method of accounting. In 2017, the corporation reported the following items: Gross profit…………………………………………

> Under what circumstances is a corporation’s assumption of liabilities considered boot in a Sec. 351 exchange?

> Maria Garcia is a CPA whose firm has prepared the tax returns of Stanley Corporation for many years. A review of Stanley’s last three tax returns by a new staff accountant, who has been assigned to the client for the first time, reveals that the corporat

> Amy, Beth, and Meg each own 100 of the 300 outstanding shares of Theta Corporation stock. Amy wants to sell her shares, which have a $40,000 basis and a $100,000 FMV. Either Beth and/or Meg can purchase Amy’s shares (50 shares each) or Theta can redeem a

> Mike Barton owns Barton Products, Inc. The corporation has 30 employees. Barton Corporation expects $800,000 of net income before taxes in 2017. Mike is married and files a joint return with his wife, Elaine, who has no earnings of her own. They have one

> Production Corporation owns 70% of Manufacturing Corporation’s common stock and Rita Howard owns the remaining 30%. Each corporation operates and sells its product within the United States, and the corporations engaged in no intercompan

> James Bowen owns 100% of Bowen Corporation stock. Bowen is a calendar year, accrual method taxpayer. During the current year, Bowen made three charitable contributions: Bowen purchased the Bates stock three years ago for $30,000. Bowen holds a 28% inter

> Alice, Bill, and Charles each received an equal number of shares when they formed King Corporation a number of years ago. King has used the cash method of accounting since its inception. Alice, Bill, and Charles, the shareholder-employees, operate King a

> Wicker Corporation made estimated tax payments of $6,000 in Year 1. On March 12 of Year 2, it filed its Year 1 tax return showing a $20,000 tax liability, and it paid the $14,000 balance at that time. On April 20 of Year 2, it discovers an error and file

> In the current year, Alpha Corporation generated $500,000 of ordinary operating income and incurred a $20,000 capital loss on the sale of marketable securities from its investment portfolio. Alpha expects to generate $500,000 of ordinary operating income

> Omega Corporation, a regular C corporation, presents you with the following partial book income statement for the current year: Omega also provides the following partial balance sheet information: You have gathered the following additional information: