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Accounting. Audit and Tax
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Subject Topic: Non Pro Rata Distribution (Topic Closed Topic Closed) Post ReplyPost New Topic
  
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taxhelp
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Joined: 23 Nov 2009
Location: United States
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Posted: 23 Nov 2009 at 15:16 | IP Logged  

When a corporation liquidates and distributes an asset on a non pro rata basis, will the entire realized loss be dissallowed, or just the portion that is distributed to a related party (i.e. >50%).

For example, suppose Corp X is owned by two shareholders.  A owns 70%, while B owns 30%.  If Corp X has a realized loss from one asset of (100K), and distributes the FMV of the asset on a 50/50 basis instead of pro rata, is the entire loss of (100K) dissallowed or just the (35K) which relates to the related party?

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