As part of a Type C reorganization, Tulsa Corporation exchanges assets having a $300,000 FMV and a $175,000 adjusted basis for $250,000 of Akron Corporation voting common stock and Akron’s assumption of $50,000 of Tulsa’s liabilities. Tulsa liquidates, with its sole shareholder, Michelle, receiving the Akron stock in exchange for her Tulsa stock having an adjusted basis of $100,000. Michelle owns 12% (2,500 shares) of Akron’s stock immediately after the reorganization.
a. What is the amount of Tulsa’s recognized gain or loss in the asset transfer? On the distribution of the stock?
b. What is Akron’s basis in the assets it receives?
c. What effect would the transfer of Tulsa’s assets to Subsidiary Corporation (controlled by Akron) have on the reorganization?
d. What are the amount and character of Michelle’s recognized gain or loss?
e. What is Michelle’s basis and holding period for her Akron stock?
f. What are the tax consequences of the transaction if Akron first transfers its stock to Akron-Sub Corporation, which then acquires Tulsa’s assets?