Question: IRC 302(b)(2) states that redemption will be treated as an exchange if the redemption is a disproportionate distribution The determination of whether a redemption qualifies

IRC 302(b)(2) states that redemption will be treated as an exchange if the redemption is “a disproportionate distribution” The determination of whether a redemption qualifies under this provision is:


a. very subjective.


b. very objective. 


Stone Corp. purchased 100% of the stock of Pearl Corp. in 1984 for $300,000. Early this year, Pearl was liquidated. Stone Corp. received all of Pearl’s assets, which had a basis to Pearl Corp. of $420,000 and an FMV of $440,000. Assume the requirements of §332 were satisfied. Will Stone Corp. recognize any gain as a result of the liquidation? 


a. yes. 


b. no. 


Refer to question #11 above. Will Pearl Corp. recognize any gain as a result of the liquidation?


a. yes.


b. no. 


Refer to question #11 above. 


The gain potential in the stock owned by Stone Corporation prior to the liquidation is: 


a. deferred until a later time.


b. eliminated, i.e., will never be recognized. 

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