Bedrock Inc. is owned equally by Barney Rubble and his wife Betty, each of whom hold 740 shares in the company. Betty wants to reduce her ownership in the company, and it was decided that the company will redeem 370 of her shares for $25,500 per share on December 31 of this year. Betty’s income tax basis in each share is $5,900. Bedrock has current E&P of $10,450,000 and accumulated E&P of $50,620,000.
a. What is the amount and character (capital gain or dividend) recognized by Betty as a result of the stock redemption, assuming only the “substantially disproportionate with respect to the shareholder” test is applied?
b. Given your answer to part (a), what is Betty’s income tax basis in the remaining 370 shares she owns in the company?
c. Assuming the company did not make any dividend distributions this year, by what amount does Bedrock reduce its E&P as a result of the redemption?