Question
A, B and C form X Corporation by transferring the following assets, each of which has been held long-term: Transferor Asset Adjusted Book FMV A
A, B and C form X Corporation by transferring the following assets, each of which has been held long-term:
Transferor Asset Adjusted Book FMV
A Equipment (all 1245 gain) $15,000 $22,000
B Inventory 7,000 20,000
B Land 25,000 10,000
C Land 20,000 50,000
In exchange, A receives 15 shares of X common stock (value-$15,000), $2,000 cash and 100 shares of X preferred stock (value - $5,000), B receives 15 shares of X common stock (value - $15,000) and $15,000 cash, and C receives 10 shares of X common stock (value-$10,000), $5,000 cash and X's note for $35,000, payable in two years. None of the transferors is a "dealer" in real estate. Assume that the preferred stock issued to A is not "nonqualified preferred stock.
(a)What are the tax consequences (gain or loss realized and recognized, basis and holding period) of the transfers described above to each shareholder and to X Corporation?
(b) What result to C in (a), above, if instead of land, C transferred depreciable equipment with the same AB and FMV as the land and an original cost to C of $50,000? See 453(i).
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