Answered step by step
Verified Expert Solution
Link Copied!

Question

1 Approved Answer

Background: You are a senior manager at a large public accounting firm located in Reno, Nevada. One of your clients, Joel Nash, also a resident

Background:

You are a senior manager at a large public accounting firm located in Reno, Nevada. One of your clients, Joel Nash, also a resident of Reno, Nevada, calls you with a tax question. Joel has operated his business as a sole proprietorship for many years but has decided to incorporate the business in order to limit his exposure to personal liability.

One problem with this plan is that the liabilities of his sole proprietorship exceed the basis of the assets to be transferred to the corporation by $700,000 ($2,000,000 liabilities - $1,300,000 assets). Therefore, even though the transaction will qualify for tax-free incorporation under the nonrecognition provisions of Code Section 351, Joel would still be required to recognize a gain of $700,000 (the extent to which the liabilities transferred exceed the aggregate basis of assets transferred).

Joel is not pleased with this result and asks you about the effect of drawing up a $700,000 note that he would then transfer to the corporation. Joel wants to know whether the note, which promises a future payment from himself to the corporation in the amount of $700,000, will enable him to avoid recognition of the gain.

Question:

In this case would the note allow Joel to avoid recognition of the gain?

Step by Step Solution

There are 3 Steps involved in it

Step: 1

blur-text-image

Get Instant Access to Expert-Tailored Solutions

See step-by-step solutions with expert insights and AI powered tools for academic success

Step: 2

blur-text-image

Step: 3

blur-text-image

Ace Your Homework with AI

Get the answers you need in no time with our AI-driven, step-by-step assistance

Get Started

Recommended Textbook for

Quality Auditing In Construction Projects

Authors: Abdul Razzak Rumane

1st Edition

1032570245, 978-1032570242

More Books

Students also viewed these Accounting questions

Question

8.1 Explain what is meant by "margin of error" in point estimation.

Answered: 1 week ago

Question

Demonstrate three aspects of assessing group performance?

Answered: 1 week ago