Question
A. Gail and John decide to form a new corporation called Titans Corporation. Gail transfer property with a basis of $25,000 and a current value
A.
Gail and John decide to form a new corporation called Titans Corporation.
Gail transfer property with a basis of $25,000 and a current value of $200,000 in exchange for 50 shares of Titans Corporation. John transfers property with a basis of $50,000 and a current value of $165,000. John also will provide accounting and tax services to Titans Corporation. John receives 50 shares in the new Titans Corporation. The value of Johns services provided is $35,000.
- What gain or income do Gail and John recognize on the exchange?
- What is Titans basis in the property transferred by Gail and Jane?
- How does Titan treat the value of the accounting services rendered by John?
B.
Jerome Howard exchanges property with a basis of $300,000 and a fair market value of $900,000 for 70% of the stock of Stooges Corporation. The other 30% of the stock is owned by Jules White who acquired his stock several years ago.
You are a CPA in private practice and Jerome comes to you and asks you whether he must report a gain on the transfer on his tax return.
Please draft a letter to your client Jerome and an associated memo to the tax files with documentation for your response.
Your memo to the files should incorporate the following sections:
FACTS
ISSUES
LAW & ANALYSIS
CONCLUSION
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