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a) In a Section 351 incorporation, Stella contributes real estate that has a built-in loss (FMV of $302,000, basis of $374,000) in exchange for 90%
a) In a Section 351 incorporation, Stella contributes real estatethat has a built-in loss (FMV of $302,000, basis of $374,000) in exchange for 90% of her new corporations stock, worth $271,000, along with $209,000 cash. What basis does the corporation take in the real estate? b) Rhonda contributes her computer equipment (FMV = $340,000, Basis = $198,200) in exchange for 90,000 shares of Legal Eagles, Inc. stock, FMV = $290,000, and a $50,000 promissory note payable to Rhonda. Jennifer contributes legal services (FMV = $85,000; Basis = $0) along with $9,500 cash, in exchange for 60,000 shares of Legal Eagles, Inc. stock, FMV =$54,000, and a 2009 Ferrari, FMV= $70,000. Has the 80% control test been satisfied by the parties?
b) Rhonda contributes her computer equipment (FMV = $340,000, Basis = $198,200) in exchange for 90,000 shares of Legal Eagles, Inc. stock, FMV = $290,000, and a $50,000 promissory note payable to Rhonda. Jennifer contributes legal services (FMV = $85,000; Basis = $0) along with $9,500 cash, in exchange for 60,000 shares of Legal Eagles, Inc. stock, FMV =$54,000, and a 2009 Ferrari, FMV= $70,000. Has the 80% control test been satisfied by the parties?
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