Question

Crane Corporation has 2,000 shares of stock outstanding. It redeems 500 shares for $370,000 when it has paid-in capital of $300,000 and E & P of $1,200,000. The redemption qualifies for sale or exchange treatment for the shareholder. Crane incurred $13,000 of accounting and legal fees in connection with the redemption transaction and $18,500 of interest expense on debt incurred to finance the redemption. What is the effect of the distribution on Crane Corporation's E & P? Also, what is the proper tax treatment of the redemption expenditures?

Answer 1

E&P $1,200,000 × 25%= $300,000 reduction

Crane Corporation would reduce its E & P in the amount of $300,000 as a result of the redemption.

This represents a 25% decrease in the amount of the E & P corresponding to the 25% stock redemption.

When a stock redemption results in sale or exchange treatment for the shareholder, the E & P account of a corporation is reduced in an amount not in excess of the ratable share of the E & P of the distributing corporation attributable to the stock redeemed.

As such, none of the expense of $13,000 of accounting and legal fees or other is deductible.