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8a,b Wilma and Bettye form a new corporation, Bam-Bam Inc. They transfer appreciated property to the corporation with each receiving 50% ownership. Right after formation
8a,b Wilma and Bettye form a new corporation, Bam-Bam Inc. They transfer appreciated property to the corporation with each receiving 50% ownership. Right after formation Wilma gave Mr. Slade half of her stock to pay a preexisting debt. She made this written promise months before incorporation. What is the best answer for whether this is a 351 or not. a. no this is not a 351 since the right types of property were not transferred b. no this is not a 351 as there were no services transferred c. Yes it is a 351 since it was just a gratuitos promise d. yes it is a 351 since they are all family e. No it is not a 351 since Wilma had committed to Mr. Slade before the transaction and Mr. Slade transferred nothing in the corporation. Tyrone and Andrew formed Blue Corporation thiree years ago. Both Tyrone and Andrew transferred appreciated property to Blue in exchange for 50 shares each in the corporation. The original transfers qlified under 351, and neither Tyrone and Andrew was taxed on the exchange. In the current year, Tyrone transfers property (worth $90,000, adjusted basis of $5,000 ) for 50 additional Blue shares. Is this a $351 transfer? a. No and the original transactions no longer are qualified as Tyrone only owns 66.67% of the stock b. Yes, if he can get Andrew just to transfera $1 in, it will qualify c. Yes Tyrone and Andrew own 100% before and after the transaction so we fine d. No and he has a $85,000 gain on the transfer e. No and he has a $5,000 gain on the transfer
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