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Grumpy, Sleepy, and Sneezy own the stock in Redbird Corporation (E&P of $900,000

ID: 2593639 • Letter: G

Question

Grumpy, Sleepy, and Sneezy own the stock in Redbird Corporation (E&P of $900,000) as follows: Grumpy, 600 shares; Sleepy, 400 shares; and Sneezy, 1,000 shares. Sleepy is Grumpy’s daughter, and Sneezy is Grumpy’s brother. Redbird Corporation redeems 400 of Grumpy’s shares (basis of $55,000) for $240,000. Grumpy purchased the stock three years ago as an investment.

Explain the tax consequences for Grumpy for this redemption including recognized gain/loss, character of that gain/loss, and the basis of his remaining Redbird stock.

If you believe this is a qualified redemption, what type of redemption is it? Show all calculations.

Explanation / Answer

It is a capital redemption(return of capital ) of 400 shares of Grumpy by Redbird Corporation. Recognised gain(on sale by) to Grumpy will be 240000-55000= 185000 It is a long-term capital gain as the stock was held for more than 1 year Basis of his remaining Redbird stock= 55000/400*200= 27500 This is a qualified stock( capital)   redemption ,as it reduces Grumpy's 3/10 ths share in Redbird Corpn. To 1/8 th -- a substantial reduction in voting power. Because the above transaction is treated as a sale of part of Grumpy's shares, the amount received is offset by the basis of the shares invested. Hence the tax amount is comparatively less than dividend distributions.