Gary D. and Lindy H. Combrink - Page 20




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               Section 301 provides in relevant part:                                 
               SEC. 301.  DISTRIBUTIONS OF PROPERTY.                                  
                    (a) In General.--Except as otherwise provided in                  
               this chapter, a distribution of property (as defined in                
               section 317(a)) made by a corporation to a shareholder                 
               with respect to its stock shall be treated in the                      
               manner provided in subsection (c).                                     
                    (b) Amount Distributed.--                                         
                         (1) General rule.--For purposes of this                      
                    section, the amount of any distribution shall be                  
                    the amount of money received, plus the fair market                
                    value of the other property received.                             
                              *    *    *    *    *    *    *                         
                    (c) Amount Taxable.--In the case of a distribution                
               to which subsection (a) applies--                                      
                         (1) Amount constituting dividend.--That                      
                    portion of the distribution which is a dividend                   
                    (as defined in section 316) shall be included in                  
                    gross income.                                                     
                         (2) Amount applied against basis.--That                      
                    portion of the distribution which is not a                        
                    dividend shall be applied against and reduce the                  
                    adjusted basis of the stock.                                      
                         (3) Amount in excess of basis.--                             
                              (A) In general.--Except as provided in                  
                         subparagraph (B), that portion of the                        
                         distribution which is not a dividend, to the                 
                         extent that it exceeds the adjusted basis of                 
                         the stock, shall be treated as gain from the                 
                         sale or exchange of property. * * *                          












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