Final answer:
The distributions to Larry and Ed are analyzed against Brown Corporation's E & P and are considered dividend income. The entire distribution amounts received by both shareholders are taxable as dividends. Larry recognizes a capital gain of $70,000 from the sale of his stock to Ed.
Step-by-step explanation:
The student's question involves several aspects of business finance, including earnings and profits (E & P), dividend income, and capital gains. The distributions made by Brown Corporation to Larry and Ed are analyzed based on the accumulated and current E & P to determine the taxable portion as dividend income. Larry's $450,000 distribution would first be offset by the $120,000 of accumulated E & P, then current E & P up to the distributed amount. Since the current E & P far exceeds the distribution, the entire $450,000 distribution is considered dividend income. Ed's $150,000 distribution would similarly be considered dividend income, as there is still enough current E & P to cover the distribution. Regarding Larry's sale of stock to Ed, Larry's basis in the stock was $200,000, and he sold it for $270,000, thus realizing a capital gain of $70,000.