At the beginning of the current year, Franklin and Jose (unr…
At the beginning of the current year, Franklin and Jose (unrelated shareholders) each own 50% of Angel Corporation (a calendar year taxpayer). In July, Franklin sold his stock to Patty for $140,000. At the beginning of the year, Angel Corporation had accumulated E & P of $240,000 and its current E & P is $280,000 (prior to any distributions). Angel distributed $300,000 on February 15 ($150,000 to Franklin and $150,000 to Jose) and distributed another $300,000 on November 1 ($150,000 to Patty and $150,000 to Jose). Patty has a dividend equal to:
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