On May 10 of the current year, Stowe Corporation distributes to its shareholder Arlene $20,000 in cash and land (a capital asset) having a $50,000 FMV. The land has a $15,000 adjusted basis (for both taxable income and E&P purposes) and is subject to a $60,000 mortgage, which Arlene assumes. Stowe has an E&P balance exceeding the amount distributed and is subject to a 34% marginal corporate tax rate.
a. What are the amount and character of the income Arlene recognizes as a result of the distribution?
b. What is Arlene’s basis in the land?
c. What are the amount and character of Stowe’s gain or loss as a result of the distribution?