Sam owns 70 percent of the stock of Club Corporation. Unrelated individuals own the remaining 30 percent. For a stock redemption of Sam's stock to be treated as an exchange under the "substantially disproportionate" test, what percentage of Club stock must Sam own after the redemption

C.Any percentage less than 50 percent

Explanation:

In relation to the law on meeting the criteria to be treated as an exchange under the "substantially disproportionate" test as stipulated by U.S. Code § 302.Distributions in redemption of stock, Sam must own the lesser of 2 options of Club Corporation stock;

1. Less than 50% of the stock after the redemption

2. Less than 80% of Sam's previous ownership percentage

= 80% * 70%

= 56%

The lesser option is that of owning less than 50% so Sam must own less than 50% of stock after the redemption to meet the requirement to be treated as an exchange under the "substantially disproportionate" test.

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