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This article aims to clarify the challenges in determining tax consequences of property distributions in Subchapter S corporations.

Property Distributions of Subchapter S Corporations: Regulation 1.1373-1(e) (2) Allocations Not Always Necessary.

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This article aims to clarify the challenges in determining tax consequences of property distributions in Subchapter S corporations.
Examines allocation of current earnings and profits (CE&P) for property distributions.
Explores how distributions are charged against CE&P and accumulated earnings.
Determining tax consequences for shareholders is often complex.
Allocations are conceptual and made solely for tax determination at the shareholder level.

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This article analyzes tax implications of property distributions in Subchapter S corporations, indicating complexities involved.

Gaffney et al. (1980) studied this question.

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