Question

Which of the following is not a related party for constructive ownership purposes under § 267? a.The taxpayer's grandmother. b.A corporation owned more than 50% by the taxpayer. c.The taxpayer's brother. d.The taxpayer's aunt. e.None of these choices are correct.

Answer 1

A). The taxpayer's aunt.

Step-by-step explanation:

Constructive ownership is demonstrated as the allocation of stock ownership from one to another taxpayer by the integrity of their relationship. For example, the parents own the stocks of their children constructively. As per the section (c) of constructive ownership under § 267, the party that cannot be a related part for constructive ownership purposes would be 'the aunt' of the taxpayer as she is not related to the taxpayer with blood either half or whole. Thus, she would not have any ownership right over the stock or shares and hence, option C is the correct answer.