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Tax II Problem
Howard Stark, envious of his son’s movie career, ventured into television, but only got a small part in a story about his inventions. So, he decided to finance his own reality show, Iron Baker. (Whether he stole the concept from Tony or it described the consistency of his bread, we are not sure).
In a recent episode he was demonstrating the proper technique to raise shortbread, but got cara-wayed and took too long. Everything went a-rye, the loaf exploded (it was filed with baking powder) and Howard was toast.
You have been asked to advise his estate on the following.
Howard’s gross estate includes:
1.1,000 shares of Stark Armaments, Inc. This is Howard’s military development company. His basis in the shares is $ 350,000. The date of death value is $1,500,000 (we took out some zeros so as to not overtax your calculators). It was a great deal of E & P—more than enough no matter what we do. The balance of the stock is owned as follows
a. Maria Stark, his wife, owns 400 shares.
b. Pepper Potts (Tony’s wife—ok I’m a couple of movies early) owns 90
c. Peggy Carter, no relation, owns the remaining 510.
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2. 610 shares of Stark Innovations, Inc. This is Howard’s commercial company.His basis in the stock was $190,000. It’s FMV at the time ofhis death was $1,100,000. It too had overwhelming E & P.The balance of the stock is owned as follows
a. Tony Stark, his son, owns 100 shares.
b. Maria owns 90 shares.
c. Pepper Potts owns 100.
d. Edwin Jarvis, the butler but otherwise no relation, owns 100.
Taxes and administration expenses are $980,000. The total estate is $6,500,000. Maria and Tony are the sole heirs of the estate.
Maria, the executor, asks you
1 What are the tax consequences to the estate if it redeems stock to pay off the taxes and expenses? Does it matter which stock is redeemed?
2 What are the tax consequences to the estate if all of its Armaments stock is redeemed by the corporation for FMV?
3 What are the tax consequences to the estate if all of its Innovation stock is redeemed by the corporation for FMV?
No stock of the other shareholders will be redeemed.
You may work in teams of no more than two, or alone. Explain your answers.
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