Sylvia Owns 25% of Cormorant Corporation, Which Sells Diamonds to Retail

question 164

Essay

Sylvia owns 25% of Cormorant Corporation, which sells diamonds to retail jewelry businesses. While Cormorant has a deficit in accumulated E & P of $56,000 at the beginning of the year, its current E & P is $500,000. Since the company had a successful year, Cormorant pays a $36,000 distribution to each of the company's four shareholders on December 15. Three shareholders receive cash, but Cormorant distributes a diamond (adjusted basis of $40,000 and a fair market value of $36,000) to Sylvia in lieu of cash. Determine the effect of distributing the diamond on Cormorant's and on Sylvia's taxable income. What is Sylvia's basis in the diamond? Was the distribution good tax planning on the part of Cormorant? Why or why not?

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Definitions:

Empowerment

Granting individuals or groups the authority and confidence to make decisions and take actions autonomously.

Coercive Power

The ability of a person to influence others through the threat of punishment or the imposition of unpleasant consequences.

Legitimate Power

A form of authority where power is given to an individual due to their position and responsibilities within an organization.

Cognitive Ability

The capacity of an individual to perform various mental activities related to learning, problem-solving, and decision-making.