Goose Corporation, with E & P of $$40,000,$ makes a cash distribution of $$50,000$ to a shareholder.The shareholder$$s basis in the Goose stock is $$20,000.$ If the distribution is not a qualifying stock redemption or in complete liquidation, the shareholder recognizes dividend income of$$40,000($the amount of Goose$$s E & P$)$ and treats the remaining $$10,000$ of the distribution as are turn of capital $($i$.$e$.,$ stock basis is reduced to $$10,000).$If the distribution is a qualifying stock redemption or is pursuant to a complete liquidation, the shareholder has a capital gain of $$30,000($$$50,000$ distribution $2$ $$20,000$ stock basis$).$ In the case of these distributions, Goose$$s E & P does not affect the shareholder$$s tax result. Prepare a memo to the tax files to address the IRS$$s determination.