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Problem - The stock of Emerald Corporation is held equally by Barney and Faye. The shareholders would like to receive, as a dividend, value of $800,000 each. The corporation has the following assets that it no longer uses.
Asset
Adjusted Basis to Emerald Corporation
Fair Market Value
Unimproved land
$1,040,000
$800,000
Chevron stock
480,000
800,000
Both assets are held as investments. Emerald Corporation has a capital loss carry-over from the previous year of $80,000 and has accumulated E & P in excess of $2,000,000.
Barney and Faye have come to you for advice. Suggest an attractive tax plan to carry out what the parties want. Write a letter (addressed to Emerald Corporation at PO Box 940, Rochester, NY 14692) describing your plan and its tax consequences.
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