A transfer of property by a corporation to A not made for an adequate and full consideration in money or money's worth is a gift to the latter from the stockholders or members of the corporation in proportion to their respective interests, except where A himself is a stockholder or member of the corporation and the transfer is a distribution to him as such from earnings or as a result of a liquidation.
NOTE: Reference: Section 15104, Revenue and Taxation Code.
Cal. Code Regs. Tit. 18, § 15104.7