Andrew, Bea, Carl, and Carl, Jr. (Carl's son), and Tetra Corporation own all of the single class of Excel Corporation stock as follows:

Andrew, Bea, and Carl are unrelated. Bea owns 75% of the Tetra stock, and Andrew owns the remaining 25%. Excel’s E&P is $100,000. Determine the tax consequences of the following independent transactions to the shareholders and Excel:

a. Excel redeems 25 of Bea’s shares for $30,000.

b. Excel redeems 10 of Bea’s shares for $12,000.

c. Excel redeems all of Carl’s shares for $30,000.

d. Assume the same facts as in Part c except the stock is redeemed from Carl’s estate to pay death taxes, and the entire redemption qualifies for sale treatment under Sec. 303. The stock has a $28,000 FMV on the date of Carl’s death. The alternate valuation date is not elected.

e. Excel redeems all of Andrew’s shares for Excel land having a $6,000 basis for both taxable income and E&P purposes and a $24,000 FMV. Assume a 34% marginal corporate tax rate.

f. Assume that Carl owns 25 shares of Excel stock and that Carl, Jr. owns the remaining 75 shares. Determine the tax consequences to Carl and Excel if Excel redeems all 25 of Carl’s shares for $30,000.

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Shareholder Shares Held Adjusted Basis Andrew 20 S3,000 Bea 30 6,000 Carl 25 4,000 Carl, Jr. 15 3,000 Tetra Corporation 10 2,000 Total 100