Question - Petrel Corporation has accumulated E & P of $85,000 at the beginning of the year. Its current-year taxable income is $320,000. On December 31, Petrel distributed business property (worth $140,000, adjusted basis of $290,000) to Juan, its sole shareholder. Juan assumes a $70,000 liability on the property. Included in the determination of Petrel's current taxable income is $16,000 of income recognized from an installment sale in a previous year. In addition, the corporation incurred a Federal income tax liability of $112,000, paid life insurance premiums of $4,500, and received term life insurance proceeds of $150,000 on the death of an officer.
A. What is Juan's gross income from the distribution?
B. What is the E & P of Petrel Corporation after the property distribution?
C. What is Juan's tax basis in the property received?
D. How would your answers to (a) & (b) change if Petrel had sold the property at its fair market value, used $70,000 of the proceeds to pay off the liability, and distributed the remaining cash and any tax savings to Juan?