Question

Puffin Corporation makes a property distribution to its sole shareholder, Bonnie. The property distributed is a car (basis of $30,000; fair market value of $20,000) that is subject to a $6,000 liability which Bonnie assumes. Puffin has no accumulated E & P and $30,000 of current E & P from other sources during the year. What is Puffin’s E & P after taking into account the distribution of the car?

Answer 1

Answer:

Puffin’s E & P after taking into account the distribution of the car is $6,000.

Explanation:

E & P will be decreased by the higher of the adjusted basis or the fair market value of the distributed property, net of any liabilities. The distribution losses will not be taken into consideration when determining E & P. Thus the current E & P of Puffin’s $30,000 is reduced by $24,000 ($30,000 basis of the car minus the liability amount). The remaining after the distribution current E & P will be $6,000.

Therefore, Puffin’s E & P after taking into account the distribution of the car is $6,000.