JBC Corporation is owned 20 percent by John, 30 percent by Brian, 30 percent by

Question

JBC Corporation is owned 20 percent by John, 30 percent by Brian, 30 percent by Charlie, and 20 percent by Z Corporation. Z Corporation is owned 80 percent by John and 20 percent by an unrelated party. Brian and Charlie are brothers. Answer each of the following questions about JBC under the constructive ownership rules of Section 267:<?xml:namespace prefix = o ns = "urn:schemas-microsoft-com:office:office" />

a. What is John's percentage ownership?

b. What is Brian's percentage ownership?

c. What is Charlie's percentage ownership? _________%

d. If Brian sells property to JBC for a $6,000 loss, what amount of that loss can be recognized for tax purposes (before any annual limitations)?

Explanation / Answer

a) john owner ship =20 + 80% of 20 = 20 =16 =36

b) 30 + 30 =60%

c) 30 + 30 = 60%

d) 0 since brain owns morethan 50% of the company directly or indirectly

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