The AB Corp. has been owned equally by individuals A and B for over five years. AB

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The AB Corp. has been owned equally by individuals A and B for over five years.

AB operates two qualified businesses, Q and R. The XYZ Corp. wishes to acquire Division Q, worth $500,000 (asset basis

$300,000), and AB wants to sell. AB Corp.

distributes the assets of Q to A and B, who thereafter sell them to XYZ. What are the tax consequences to all parties if:

a. ‘The distribution does qualify as a partial liquidation?

b. The distribution does not qualify under Code Sec. 302(b)(4)?

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CCH Federal Taxation Basic Principles 2020

ISBN: 9780808051787

2020 Edition

Authors: Ephraim P. Smith, Philip J. Harmelink, James R. Hasselback

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