Problem NO: 31

Miley decided to terminate the S corporation election of her solely owned corporation on October 17, 2023 (effective immediately), in preparation for

Miley decided to terminate the S corporation election of her solely owned corporation on October 17, 2023 (effective immediately), in preparation for taking it public.  Miley had previously elected S corporation status on January 1, 2022.  At the time of the election, the corporation had an accumulated adjustments account balance of $150,000 and $450,000 of accumulated E&P from prior C corporation years, and Miley had a basis in her S corporation stock of $135,000.  During 2024, Miley’s corporation reported $0 taxable income or loss.  Also, during 2024 the corporation made distributions to Miley of $80,000 and $60,000.  How are these distributions taxed to Miley assuming the following?

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