Question :
Distribution of Appreciated Property. In the current year, Sedgwick Corporation has $100,000 of current and accumulated E&P. On March 3, Sedgwick distributes to its shareholder Dina a parcel of land (a capital asset) having a $56,000 FMV. The land has a $40,000 adjusted basis (for both taxable income and E&P purposes) to Sedgwick and is subject to an $8,000 mortgage, which Dina assumes. Consider a 34% marginal corporate tax rate.
a. What is the amount and character of the profits Dina recognizes as a result of the distribution?
b. Evaluate Dina's basis in the land?
c. What are the amount and character of Sedgwick's profit or loss as a result of the distribution?
d. What effect does the distribution have on Sedgwick's E&P?