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:

Bank Loan

A sum of money lent by a bank to a borrower for a set period at an agreed interest rate.

Interest Expense

The cost incurred by an entity for borrowed funds over a period of time.

Interest Payable

A liability account representing the amount of interest expense that has been incurred but not yet paid.

Accrued Expense

Expenses that have been incurred but not yet paid or recorded in the financial statements, reflecting obligations that a business has taken on.