Question
Birch Corp., a calendar-year corporation, was formed three years ago by its sole shareholder, James, who has operated it as an S corporation since its
Birch Corp., a calendar-year corporation, was formed three years ago by its sole shareholder, James, who has operated it as an S corporation since its inception. Last year, James made a direct loan to Birch Corp. in the amount of $6,600. Birch Corp. has paid the interest on the loan but has not yet paid any principal. (Assume the loan qualifies as debt for tax purposes.) For the year, Birch experienced a $34,700 business loss.
What amount of the loss clears the tax-basis limitation, and what is Jamess basis in his Birch Corp. stock and Birch Corp. debt in each of the following alternative scenarios?
a. At the beginning of the year, James's basis in his Birch Corp. stock was $46,100 and his basis in his Birch Corp. debt was $6,600.
b. At the beginning of the year, James's basis in his Birch Corp. stock was $10,300 and his basis in his Birch Corp. debt was $6,600.
c. At the beginning of the year, James's basis in his Birch Corp. stock was $0 and his basis in his Birch Corp. debt was $6,600.
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