Problem
Trumbull (an individual) owns 100% of the stock of Storrs, Inc. (a C corporation) and 100% of the stock of Jungle, Inc. (another C Corporation). Jungle, Inc. is very successful and has millions in earnings and profits. Storrs has not fared so well and has no earnings and profits. In the current year, Storrs ran out of cash and could not make its payroll. Because of this situation, Trumbull directed Jungle, Inc. to pay $100,000 in wages to employees of Storrs. The $100,000 payment was not structured as a loan. [Assume that proper tax was withheld from the wages, the wages were still reported to workers on Form W-2, etc.-i.e., this is not a payroll tax issue.]
What are the tax consequences, if any, to Trumbull? Briefly explain. Cite any relevant authority.