Accounts-AW330

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The stock of X is owned equally by two shareholders: Y (an individual with a stock basis of $100) and A (an individual with 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 expenses (X has always been an S Corporation) as follows:
 

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 expense………………………….$430
Noncapital expenses not deductible under Section 162(e)…………$90
Capital Losses (See Section 1211(a))…………………………………………..$146
Total……………………………………………………………………………………………$666
Net………………………………………………………………………………………………$134
 
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What is X’s E&P?
 

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 non-separately computed income for each shareholder.)
 

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 distribution for each shareholder.)
 

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, show calculations where appropriate. (1) 1374 tax; (2) 1375 tax (calculate excessive passive income) and consequences, and (3) AAA and E&P and basis.
 
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