Jorge contributed land he held as an investment (fair market value $120,000; basis $55,000) and inventory (fair market value $80,000; basis $75,000) to ABC Corporation in exchange for 50 percent of the ABC stock (50 shares valued at $160,000) and $40,000 cash in a qualifying §351 exchange.
a. What amount of gain does Jorge recognize on the exchange? What is the character of the gain? What would be Jorge's basis in his ABC stock after the exchange?
b. Assume the same facts except that Jorge received $40,000 of business property from ABC instead of $40,000 cash. What is the amount and character of gain Jorge would recognize on the exchange?
c. Assume the original facts in this example except that the inventory had an adjusted basis of $90,000 so that Jorge realized a $10,000 loss on the inventory (he still realized a $65,000 gain on the land). How much gain or loss would he recognize on the exchange?