Question

Seven years ago, Eleanor transferred property she had used in her sole proprietorship to Blue Corporation for 2,000 shares of Blue Corporation in a transaction that qualified under § 351. The assets had a tax basis to her of $400,000 and a fair market value of $700,000 on the date of the transfer. In the current year, Blue Corporation (E & P of $1 million) redeems 600 shares from Eleanor for $260,000 in a transaction that qualifies for sale or exchange treatment With respect to the redemption, Eleanor will have a: a. $260,000 capital gain. b. $140,000 capital gain. c. $260,000 dividend. d. $140,000 dividend.

Answer 1

With respect to the redemption, Eleanor will have a: • $140,000 capital gain In the context of transaction treated as a return of a portion on her investment. She is treated as having sold 600 of her shares in Blue Corporation (basis of $120,000) for $260,000. As a result, Eleanor's capital gain from the sale or exchange = $260,000 - $120,000 = $140,000.