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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)?

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Answer:

Part (a)  

The percentage ownership of Mr. John is 20% + (80% x 20%) = 36%

Part (b)

The percentage ownership of Mr. Brian is 30% + 30% = 60%

Part (c)

The percentage ownership of Mr. Charlie is 30% + 30% = 60%

Part (d)

The amount that could be recognized for the purposes of tax would be $0, as Mr. Brian owns more than half that is more than 50% of XYZ Corp. either directly or indirectly.

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