Comment reviews interpretations of S corporation cash distributions amid conflicting scenarios involving Previously Taxed Income.
Jamison and Dilley (JD) in "Subchapter S in Transition" [1984] put forth a questionable interpretational procedure for handling S corporation cash distributions where a shareholder has Previously Taxed Income (PTI). The JD article presents two different PTI scenarios; one where the S corporation does not have accumulated earnings arid profits (AEP) and one where AEP exists. The solutions JD supply for these examples seem to disagree. In this Comment, we briefly review the relevant provisions which affect the tax treatment of S corporation cash distributions in these special cases, and then examine the apparently contradictory examples.
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Reeder et al. (1985) studied this question.
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