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Attached is the questions about business enterprise taxation. Thank you. 1. A, B and C form X Corporation by transferring the following assets, each of
Attached is the questions about business enterprise taxation. Thank you.
1. A, B and C form X Corporation by transferring the following assets, each of which has been held long-term: Transferor A B C Asset Adj. Basis Equipment (all 1245 gain) $15,000 F.M.V $22,000 Inventory 7,000 20,000 Land 13,000 10,000 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). 2. A organized X corporation by transferring the following: inventory with a basis of $20,000 and a fair market value of $10,000 and unimproved land held for several years with a basis of $20,000, a fair market value of $40,000 and subject to a recourse debt of $30,000. In return, A received 20 shares of X stock (fair market value, $20,000) and X took the land subject to the debt. (1) Assuming no application of Section 357 (b), how much gain, if any, does A recognize and what is A's basis and holding period in the stock? (2) What result in (a), above, if the basis of the land were only $5,000? (3) In (2), above, what is the character of A'S recognized gain under Reg. 1.357-2(b)? Does this result make sense? How else might the character of A's gain be determined? (4) In (2), above, what is X Corporation's basis in the properties received from A? (5) What might A have done to avoid the recognition of gain in (2), aboveStep by Step Solution
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