Carrot Corp, Inc

Carrot Corp, Inc. owns and operates a carrot farm. Shawn formed Carrot Corp by contributing farmland with an adjusted basis of $95,000 in exchange for 100 shares of stock in 1980. Shawn owns the only stock in Carrot Corp. Shawn made this transaction pursuant to Section 1244. At the time of the transaction, the farm was worth $140,000.

In 1990, Shawn gave 20 shares to his son Andrew, and ten shares to his son Brian. Brian and Andrew both worked in the management of Carrot Corp. At that time, the value of the gifts were $27,000 each. Shawn correctly did not pay a gift tax on the shares. His main reason for the gift was to reward his sons with equity in the company for their great work. In addition, he also wanted to place some of the taxes from Carrot Corp dividends on his sons.

In 2005, Andrew and Brian got into a fight over diversifying the farmland to make additional variations in produce. The fights became so tense that they all decided to buy out Brian