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Assume the land's FMV is $150,000 and Barton's basis in the land is $10,000. He exchanges the land for 15,000 additional shares of newly issued

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Assume the land's FMV is $150,000 and Barton's basis in the land is $10,000. He exchanges the land for 15,000 additional shares of newly issued Green Corporation stock and each family member simultaneously purchases 100 shares of newly issued common stock. Assume the land is worth $150,000, Barton's basis in the land is $10,000, and he will receive 15,000 additional shares in exchange for the land. One of the other shareholders is willing to contribute enough to the corporation such that both that shareholder and Barton will be treated as transferors. Specifically, the shareholder who is willing to help will contribute enough property to the corporation at the same time as Barton's exchange to satisfy section 351 and to avoid the Reg. 1.351-1(a)(1)(ii). What is the fewest number of new shares that the other shareholder must receive for property in order for the simultaneous transfer to qualify for non-recognition per Section 351 ? 9. In 2002 , Barton organized Green Corporation by exchanging $200,000 for all of Green Corporation's 20,000 shares of common stock. Over the years, Barton gifted shares of stock to members of his family. As a result, Barton's wife and his three children each own 4,000 shares of Green Corporation. Barton owns the remaining 4,000 shares. Barton is considering a corporate expansion in which he would contribute land to the corporation. The land is property that he purchased 10 years ago and that holds as an investment. Evaluate the following independent scenarios. Hint: Rev. Rul, 56-613, 1956-2 C.B. 212 i. Assume the land's FMV is $150,000 and Barton's basis in the land is $10,000. He exchanges the land for 15,000 additional shares of newly issued Green Corporation stock

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