Sylvia Owns 25% of Cormorant Corporation

question 165

Essay

Sylvia owns 25% of Cormorant Corporation. Cormorant 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:

Specialization

The process of focusing on and becoming an expert in a particular field or task, potentially leading to increased efficiency and productivity.

Particular Product

A specific good or service that is distinct among others due to unique characteristics or qualities.

Opportunity Cost

The cost of forgoing the next best alternative when making a decision or taking an action.

Moving From Point

The process of going from one position or condition to another, often used in discussions about changes in economic indicators or market positions.