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Clark, Bruce, and Diana, unrelated individuals, own all of the stock in Trinity

ID: 2544092 • Letter: C

Question

Clark, Bruce, and Diana, unrelated individuals, own all of the stock in Trinity Corporation (E & P of $1.2 million) as follows: Clark, 1,500 shares; Bruce, 300 shares; and Diana, 200 shares. Trinity redeems 900 of Clark’s shares (basis of $210,000 in the shares redeemed) for $625,000. With respect to the distribution in redemption of the stock:

Clark has a capital gain of $415,000.

Clark has a capital gain of $625,000.

Clark has dividend income of $415,000.

Clark has dividend income of $625,000.

None of the above.

a.

Clark has a capital gain of $415,000.

b.

Clark has a capital gain of $625,000.

c.

Clark has dividend income of $415,000.

d.

Clark has dividend income of $625,000.

e.

None of the above.

Explanation / Answer

Answer- D. Clarke has dividend income of 625000.

Explanation- according to section 302(b)(2), a disproportionate stock redemption qualifies for sale/exchange treatmenr if both the following conditions are met-

Since the second condition is not met, the redemption will be treated as dividend income to clarke.