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:

Depreciation

Allocating the expense of a tangible asset across its life of utility in a systematic manner.

Manufacturing Equipment

Tools, machinery, and other durable assets used in the process of producing goods in a manufacturing setting.

Cost of Goods Manufactured

The total cost incurred to manufacture products within a specific period, including materials, labor, and overhead, ready for sale.

Work in Process

Partially finished goods or goods in the process of being produced in a manufacturing setting.