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Larry, the sole shareholder of Brown Corporation, sold his Brown stock to Ed on July 30 for $270,000. Larry’s basis in the stock was $200,000 at the beginning of the year. Brown had accumulated E & P of $120,000 on January 1 and has current E & P of $240,000. During the year, Brown made the following distributions: $450,000 of cash to Larry on July 1 and $150,000 of cash to Ed on December 30. How will Larry and Ed be taxed.

Brown Corporation carries $240,000 in their current E&P of and the amount is assigned on the basis of pro-rata basis for the two allocations done in that year. Thus, $180,000 of their current E&P is assigned to Larry’s distribution [$240,000 current E&P × ($450,000 distribution to Larry/$600,000 total distributions)] and $60,000 is assigned to Ed’s assigned [$240,000 current E&P × ($150,000 distribution to Ed/$600,000 total distributions)]. Collected E & P is applied in consecutive order beginning with the earliest distribution.
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