James owns 100 shares of Price Company which are Section 306 stock. He also owns 300 shares of its common stock. He wants to dispose of these shares in 2013 and is considering several options. Indicate the tax consequences of each option.
a. Making a gift of the stock to his son.
b. Selling all his stock (common and preferred) to an unrelated third party.
c. Selling all his stock (common and preferred) to Price Company in a Code Sec. 302(b)(3) redemption.
d. Selling the 100 shares to Robert Thomas, assuming that Price will have no E&P in 2013.
e. Same as (d), except Price will have E&P in 2013.
f. Having Price redeem the 100 shares in 2013, assuming that Price will have no E&P in 2013.
g. Same as (d), except Price will have E&P in 2013.