Question
As part of a Type C reorganization, Tucson Corporation exchanges assets having a $170,000 FMV and a $230,000 adjusted basis for $150,000 of Reno Corporation
As part of a Type C reorganization, Tucson Corporation exchanges assets having a $170,000 FMV and a $230,000 adjusted basis for $150,000 of Reno Corporation voting common stock and Reno's assumption of $20,000 of Tucson's liabilities. Tucson liquidates, with its sole shareholder, Pat,
receiving the Reno stock in exchange for her Tucson stock having an adjusted basis of $80,000. Pat owns 77% (2,500 shares) of Reno's stock immediately after the reorganization.
a. What is the amount of Tucson's recognized gain or loss in the asset transfer? On the distribution of the stock?
b. What is Reno's basis in the assets it receives?
c. What effect would the transfer of Tucson's assets to Subsidiary Corporation (controlled by Reno) have on the reorganization?
d. What are the amount and character of Pat's recognized gain or loss?
e. What is Pat's basis and holding period for her Reno stock?
f. What are the tax consequences of the transaction if Reno first transfers its stock to Reno-Sub Corporation, which then acquires Tucson's assets?
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