Several years ago, Brian formed Sigma Corporation, a retail company ineligible for the U.S. production activities deduction. Sigma uses the accrual method of accounting. In 2014, the corporation reported the following items:

Gross profit ...................................................... $290,000

Long-term capital gain ............................................ 20,000

Tax-exempt interest received........................................7,000

Salary paid to Brian .................................................. 80,000

Payroll tax on Brian's salary (Sigma's share) ...................6,120

Depreciation ......................25,000 ($21,000 for E&P purposes)

Other operating expenses ........................................ 89,000

Dividend distribution to Brian .................................. 60,000

In addition to owning 100% of Sigma's stock, Brian manages Sigma's business and earns the $80,000 salary listed above. This salary is an ordinary and necessary business expense of the corporation and is reasonable in amount. The payroll tax on Brian's $80,000 salary is $12,240, $6,120 of which Sigma pays and deducts, and the other $6,120 of which Brian pays through Social Security withholding. Brian is single with no dependents and claims the standard deduction.

a. Calculate Sigma's and Brian's 2014 taxable income and total tax liability, as well as heir combined tax liability. Also, calculate the corporation's current E&P after the dividend distribution.

b. Assume instead that Brian operates Sigma as a sole proprietorship. In the current year, the business reports the same operating results as above, and Brian withdraws $140,000 in lieu of the salary and dividend. Assume Brian's self-employment tax is $19,220. Compute Brian's total tax liability for 2014.

c. Assume a C corporation such as in Part a distributes all of its after-tax earnings. Compare the tax treatment of long-term capital gains, tax-exempt interest, and operating profits if earned by a C corporation with the tax treatment of these items if earned by a sole proprietorship?