Question
3.0 Determine the tax consequences for the formation of a C Corporation by the following persons. Assume that value given is equal to value received.
3.0 Determine the tax consequences for the formation of a C Corporation by the following persons. Assume that value given is equal to value received.
Transferor | AB | FMV | Debt Relief | Depreciation | # of shares received | Cash received |
From G | ||||||
Notes Receivable | 100,000 | 100,000 | ||||
Machine Tools | 60,000 | 30,000 | ||||
Truck | 100,000 | 270,000 | 300,000 | 250 | 30,000 | |
Depreciation Recapture on Truck | 70,000 | |||||
From H | ||||||
Accounts Rec. | 0 | 220,000 | ||||
Machinery | 200,000 | 240,000 | 200,000 | 500 | 120,000 | |
Equipment | 85,000 | 140,000 | ||||
From C | ||||||
Legal Advice | ? | 250,000 | 100 | |||
Cash | 65,000 | 65,000 | ||||
a. Assuming IRC Section 351 applies, how much gain, if any, must G recognize (10)?
b. Assuming IRC Section 351 applies, what will be G's basis in the Z Corporation stock (10)?
c. Assuming IRC Section 351 applies, what will be Z Corporation's basis in the Truck and machine tools--state separately (10)?
d. Assuming IRC Section 351 applies, how much gain, if any, must H recognize (10)?
e. Assuming IRC Section 351 applies, what will be H's basis in the Z Corporation stock (10)?
f. Assuming IRC Section 351 applies, how much gain or loss must C recognize if the services
are to be rendered at a future date? Assume that C will forfeit the stocks if such services are not
performed (5)
g. Assuming IRC Section 351 applies, how will Z treat the value of C's services--state tax authority
(5)?
Step by Step Solution
There are 3 Steps involved in it
Step: 1
Get Instant Access to Expert-Tailored Solutions
See step-by-step solutions with expert insights and AI powered tools for academic success
Step: 2
Step: 3
Ace Your Homework with AI
Get the answers you need in no time with our AI-driven, step-by-step assistance
Get Started