1)Whipple Corporation exchanges several pieces of office furniture for 10 file cabinets that the Go-Along Corporation no longer needs. Go-Along also provides Whipple a pair of season tickets for the local hockey team. The file cabinets have a value of $2,500 and a basis of $3,000.
Go-Along paid $400 face value for the tickets. The office furniture has a basis of $1,250 and a value of $2,900.
TASK:
In a Word document, provide answers to the following:
a. What are Whipple's and Go-Along's realized and recognized gains or losses?
b. What are their deferred gains or losses?
c. What are their bases in the acquired properties?
d. What alternative transaction would you suggest to Whipple?
Justify your answers with rationales & provide specific examples to illustrate your views.
(2) The Kammerling Corporation has $250,000 of taxable income. It distributes $100,000 of that income as a dividend to its sole shareholder whose other income puts him in the 35 percent marginal tax bracket.
TASK:
Calculate the effective tax rate on the corporation's $250,000 of taxable income?
(3) Blanton Corporation had a deficit in its current earnings and profits of $36,500 for the current year. It has $75,000 in accumulated earnings and profits. The corporation made two distributions to its shareholders. On April 30, it distributed $40,000, and on November 30, it distributed $20,000.
Task:
When the corporation sends out its 1099-DIV forms to its shareholders, how much of the distribution will be taxable to the shareholders as dividends?

Solutions

1)

a. Whipple: ($2,500 + $400 boot) amount received - $1,250 basis = $1,650

realized gain; $400 gain recognized. (The tickets are boot.) Go-Along has a $500

loss [$2,900 amount received – ($3,000 basis of file cabinets + $400 tickets)]

realized but none is recognized.

b. Whipple defers $1,250 gain ($1,650 – $400); Go-along defers $500 loss.

c. Whipple’s file cabinets: $2,500 - $1,250 gain deferred = $1,250 basis; tickets =

$400 basis. (Alternative basis calculation: $1,250 basis of office furniture + $400

gain recognized - $400 boot received = $1,250.) Go-Along’s office furniture:

$2,900 + $500 deferred loss = $3,400 basis. (Alternative basis calculation: $3,000

basis of file cabinets + $400 basis of tickets + 0 gain recognized – 0 boot received

= $3,400.)

d. The only way Whipple could avoid recognizing the $400 gain would be to get

additional like-kind property for the office furniture instead of the tickets. Go-

Along, however, has a realized and unrecognized loss; it would have been better

off to sell its file cabinets rather than exchange them. Go-Along purchasing the office furniture from Whipple would cause recognition of the entire gain; thus, it

appears that this exchange is a compromise where both parties “gave” a little.

2)

To answer the question, the actual tax must be calculated.Tax for the corporation is computed inlayers:
1-50K = $7500
50-75K = $6250
75-100K = $8500
100K-250K = $58500
Total tax (federal only) = $80,750
Effective rate is 80750 / 250000 = 32.3%
Marginal rate is 39%
Corporate Income Tax Rates--2008, 2007, 2006
Taxable income over Not overTax rate
$0 $50,000 15%
50,000 75,000 25%
75,000 100,000 34%
100,000 335,000 39%
335,000 10,000,00034%

3)

April 30 distribution: 120/365 x $36,500 = $12,000 deficit in CE&P as of April 30.

$75,000 AE&P - $12,000 deficit = $63,000 AE&P as of that date; thus all $40,000

of the distribution is dividend.

November 30 distribution: 334/365 x $36,500 = $33,400 deficit in CE&P. $75,000

- $33,400 - $40,000 dividend = $1,600 AE&P.

Thus, $41,600 of the total distribution is a taxable dividend.