Question
Except as otherwise stated, A starts out with non-depreciable real property (a capital asset) worth $100 (adjusted basis $40) and ends up with cash of
Except as otherwise stated, A starts out with non-depreciable real property (a capital asset) worth $100 (adjusted basis $40) and ends up with cash of $50 plus a 50% interest (worth $50) in, a newly organized corporation that owns the property. For each part, determine the following: i. As amount realized ii. As gain or loss realized iii. As gain or loss recognized in the character thereof iv. A's basis in the X stock received v. As holding period for the X-stock received (tack or not?) vi. X corporations basis in the property received vii. X corporations holding period for the property received (text or not?) viii. The amount and character of Xs gain if X immediately sells the property for $100 (a) Al transfers the property to X in exchange for all of Xs stock. Shortly thereafter, Al sells half of his X stock to Barbara for $50 and either a. The stock sale is a separate event from the prior incorporation transaction; or b. The stock sale is an integral part of the incorporation plan. How would the result be different if the basis for Al's property were $200 rather than $40? (b) A sells a half interest in the property to B for $50. A and B then jointly transfer their property interest to X Corporation in exchange for Xs stock. (c) A and B jointly organize X Corporation. A transfers his property to X in exchange for $50 in cash and half of X Corporations stock. B transfers $50 in cash to X in exchange for the other half of Xs stock.
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