Question
Ellen and Dan form Crane Corp with the following investments: Ellen transfers cash of 300,000, and Dan transfers land worth 320,000. The land has an
Ellen and Dan form Crane Corp with the following investments: Ellen transfers cash of 300,000, and Dan transfers land worth 320,000. The land has an adjusted basis to Dan of 290,000. Each of the transferors receives 50% of the stock of Crane Corp. In addition to the stock, Dan receives a 20,000 note from Crane.
a. Do the transfers qualify under Sec 351?
b. What is Dan's realized and recognized gain (loss) on the exchange?
c. What is Dan's basis in the stock and the note?
d. What is Crane Corp's basis in the land?
e. Re-do above assuming that instead of issuing the $20,000 note, Crane assumes Dans $20,000 mortgage on the land.
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