In year one, Argonaut Corporation distributed nonconvertible nonvoting preferred stock worth $1,000 to each of its two unrelated equal common shareholders, Jason and Vera. The Argonaut common stock owned by each of the shareholders had a basis of $2,000 prior to the distribution and a value of $3,000 immediately after the distribution. At the time of the distribution, Argonaut had $2,000 of earnings and profits. In year three, Argonaut had $3,000 of earnings and profits.
(a) What are the tax consequences to Jason, Vera, and Argonaut of the distribution of preferred stock in year one?
(b) What results to Vera and Argonaut if Vera sells her preferred stock to Carl, and unrelated party, for $1,000 in year three?
(c) Same as (b), above, except that Vera sells her preferred stock to Carl for $1,750?
(d) Same as (b), above, except that Argonaut had no earnings and profits at the time of the distribution of the preferred stock?
(e) What results if Jason gives his preferred stock to his grandson, Claude, and Claude later sells the stock for $1000? What if Jason dies and bequeaths his preferred stock to Claude?
(f) What result if Jason contributes his preferred stock to a public charity?
(g) What results to Jason and Argonaut if in year three the corporation redeems half of Jason’s common stock for $5,000 and all of his preferred stock for $1,500?
(h) Same as (g), above, except the corporate bylaws require unanimous shareholder agreement for corporate action, and the bylaws may be amended only with the concurrence of more that 75 percent of the shareholders.
(i) Same a (g), above, except that Argonaut has no accumulated or current earnings and profits in year three.