Pennypincher Corp has 100 shares of stock outstanding owned by the following tax

Question

Pennypincher Corp has 100 shares of stock outstanding owned by the following taxpayers: Shareholder Shares Owned Mr Penny 30 Mrs Penny 10 John (Mr Pennys son 10 Abby (the Pennys granddaughter) 10 Buddy Penny (Mr Pennys brother) 20 P Partnership (Mr Penny is a 20% partner) 10 PPP Corp (Mr. Penny is a 40% shareholder) 10 None of Mr Pennys relatives the partnership or the corporations are partners in P or shareholders in PPP. Under the constructive ownership rules of Section 318, what percentage of Pennypincher Corp does Mr. Penny own?

Explanation / Answer

Under the constructive ownership rules of section 318, the percentage of Pennypincher Corp. which Mr Penny owns is 62 %.

He owns 30% directly plus another 32% indirectly (10 + 10 + 10 + 2) for a total of 62%.

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