Question
Corporation W owns 100% of the common stock of Corporation Z with a basis of $300. Z owns a rental building (its only asset) with
Corporation W owns 100% of the common stock of Corporation Z with a basis of $300. Z owns a rental building (its only asset) with a gross fair market value of $3,000, subject to a non-recourse mortgage of $3,300 . Zs adjusted basis for this building is $900. Z has $600 of E&P. Z is on the accrual method of accounting and reports on the calendar year. Z and W do not report on a consolidated basis. Z distributes the building to W in complete liquidation and W sells the building to Corporation V for $1,800 cash, subject to the debt. Same facts as above, except that the liability on the building is $3,300 rather than $1,200.
a. W recognizes no gain or loss on the liquidation under Section 332.
b. Z recognizes $2,400 gain under Section 336.
c. Neither of the above.
d. Both A and B of the above.
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