Amounts distributed in complete liquidation of a corporation are to be treated as full payment for all stock issued. Amounts distributed in partial liquidation are to be treated as full payment for the stock which was canceled or redeemed.
The gain or loss to a shareholder from a distribution in liquidation is to be determined by comparing the amount of the distribution with the cost or other basis of the stock. In the case of amounts distributed in partial liquidation (other than a distribution pursuant to a reorganization plan as described in ACA 26-51-412 ), the part of such distribution which is properly chargeable to the capital account shall not be considered a distribution of earnings or profits within the meaning of ACA 26-51-411 for the purpose of determining the taxability of a subsequent distribution by the corporation.
1.26 Ark. Code R. 51-413