The stock of Emerald Corporation is held equally by Barney and Faye. The shareholders would like to receive, as a dividend, value of $800,000 each.
The corporation has the following assets that it can spare:

Both assets are held as investments. Emerald Corporation has a capital loss carryover from the previous year of $80,000 and has accumulated E & P in excess of $2 million.
Barney and Faye have come to you for advice. Suggest an attractive tax plan to carry out what the parties want. Write a letter (addressed to Emerald Corporation at PO Box 940, Rochester, NY 14692) describing your plan and its tax consequences.

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Adjusted Basis to Fair Market Asset Unimproved land Chevron stock Emerald Corporation Value $1,040,000 $800,000 800,000