In the current year, Dick, Evan, and Fran form Triton Corporation. Dick contributes land (a capital asset) having a $50,000 FMV in exchange for 50 shares of Triton stock. He purchased the land three years ago for $60,000. Evan contributes machinery (Sec. 1231 property purchased four years ago) having a $45,000 adjusted basis and a $30,000 FMV in exchange for 30 shares of Triton stock. Fran contributes services worth $20,000 in exchange for 20 shares of Triton stock.
a. What is the amount of Dick's recognized gain or loss?
b. What is Dick's basis in his Triton shares? When does his holding period begin?
c. What is the amount of Evan's recognized gain or loss?
d. What is Evan's basis in his Triton shares? When does his holding period begin?
e. How much income, if any, does Fran recognize?
f. What is Fran's basis in her Triton shares? When does her holding period begin?
g. What is Triton's basis in the land and the machinery? When does its holding period begin? How does Triton treat the amount paid to Fran for her services?