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The Internal Revenue Service also cites Basic as authority for the disallowance of dividend treatment for the distribution of the unwanted assets in this case.

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On the payable date, the company deposits the funds for disbursement to shareholders with the Depository Trust Company (DTC).4) 302(b)(4) stock redemption occurs after a partial liquidation (measured by reference to events at the corporate level). After the redemption, Don owns 48.1% of the value of all common stock outstanding (,000 out of ,000 of total value). No acquisition of stock by a relative or from a relative within the prior ten years unless income tax avoidance not one of the principal purposes for that acquisition. Redeeming shareholder retained the right to designate his lawyer (nominee) to be on the corporation s board to protect the former shareholder s creditor interest.4 Basis Allocation Issues p.196 When a stock redemption is treated as a dividend distribution: what happens to the tax basis of the disappeared shares? 5 Stock Redemptions & Corporate Level Treatment p.197 1) 311 gain recognition occurs upon a corporate distribution of appreciated property in a stock redemption transaction, but no loss recognition is permitted. To qualify the redemption as an exchange, Don would have to own below 42.66% of the total common stock (80% of 53.33%). Attribution of ownership rules can preclude a complete termination, unless the ownership attribution rules are made inapplicable. 0 cash 0x escrowed Corporation Majority Shareholder Held: Having one s lawyer (an agent) on the Board violates the complete termination requirement of 302(c)(2)(A)(i).The (purchasers) did not agree to pay the stockholders .50 or any other sum from the surplus.

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It declined the original offer and proposed to cast the sale of the stock in a two step transaction.

2) 302(b)(2) the substantially disproportionate redemption exception. After the redemption, Don owns 42.9% (30 of 70 shares). WM Lynch Co Tax Court held the post-redemption arrangement was not a prohibited interest.