Question
Citron enters into a Type C restructuring with Ecru. Ecru transfers $800,000 of its voting stock for Citron's $1,200,000 assets (basis $600,000) and $400,000 liabilities.
Citron enters into a Type C restructuring with Ecru. Ecru transfers $800,000 of its voting stock for Citron's $1,200,000 assets (basis $600,000) and $400,000 liabilities. Citron retains one asset, land, which it distributes to its sole individual shareholder, Electra. The land is valued at $130,000, and its basis is $80,000. Electra's basis in her Citron stock is $970,000.
Complete each statement below that outlines the income tax consequences for Citron, Ecru, and Electra, including Ecru's basis in the assets it receives from Citron and Electra's basis in the Ecru stock she receives. Assume the transaction meets the 368 requirements for a "Type C" reorganization.
If an amount is zero, enter "0" and select "gain or loss" from the dropdown.
a. Citron: Recognizes $_________ (gain / loss / gain or loss) on the land distributed to Electra.
b. Ecru: Recognizes $_________ (gain / loss / gain or loss) on the transfer of voting stock for Citron's assets. Ecru's basis in the assets received from Citron is $_________.
c. Electra: Recognizes $_________ of her (gain / loss / gain or loss) . Electra 's basis in the new stock is $_________.
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