In forming Parts Inc. as a corporation, Candice transferred inventory to Parts Inc. in exchange for 30 percent of the corporation's stock (60 shares valued at $130,000). The inventory's fair market value was $147,000 and its adjusted tax basis to Candice was $75,000. The inventory was subject to a $17,000 liability that Parts Inc. assumed on the transfer. Candice borrowed the $17,000 from the bank (using the inventory as collateral) shortly before transferring the inventory to Parts Inc. and she used the loan proceeds to pay for a family vacation to Europe.
a. Assuming the transfer qualifies under §351 and that the liability has a tax-avoidance purpose, what gain or loss will Candice recognize on the transfer?
b. Assuming the original facts, what is Candice's basis in the stock she received in the exchange?
c. Suppose the liability does not have a tax-avoidance purpose, what gain will Candice recognize on the transfer?
d. Assuming the facts in part (c), what is Candice's basis in the stock she received in the exchange?