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Corporation ABC Inc. has the following shareholders:
o John 50 shares of voting common stock
o Peter 25 shares of voting common stock
o Paul 15 shares of voting common stock
o Luke 10 shares of voting common stock
o Matthew 100 shares of non-voting convertible preferred stock (1 share of voting common for every 10 shares of preferred)
ABC makes the following distribution:
* John 100 shares of common voting
* Peter 50 shares of common voting
* Paul 30 shares of common voting
* Luke 20 shares of convertible non-voting preferred stock
* Matthew 10 shares of convertible preferred stock
The above distribution is taxable under Section 301 for who?
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