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Corporation Z had accumulated earnings and profits of $75,000 as of January 1, Year 1. On April 1, Year 1, Z distributed $80,000 in cash to Ms. Jones, Z's sole shareholder. Z had an operating loss of $76,000 for Year 1. Ms. Jones had an adjusted basis of $65,000 in her stock before the distribution. What is the amount of Corporation Z's accumulated earnings and profits on December 31, Year 1?

$(57,000) Sec. 312(a) provides that E&P of a corporation shall be decreased by the amount of money distributed. This decrease is limited to the amount of E&P of the corporation. The current-year E&P deficit is assumed to occur ratably during the year. Assuming that each month has 30 days, the E&P deficit through March 31 of $19,000 ($76,000 × 3/12) reduces accumulated E&P to $56,000. The first $56,000 of the distribution comes out of accumulated E&P. The remaining $24,000 of the distribution is a return of capital. The $57,000 of current E&P deficit ($76,000 - $19,000) from April 1 through December 31 is the current E&P deficit at year end.