Facts Applicable to Questions 7-8: Allison owns a building constituting Section 1231 property with FMV of $500,000 and A/B of $600,000. Allison contributes the building to a corporation (LossCo) in exchange for 100% of LossCos stock.

7. How much gain or loss (if any) is recognized by Allison upon the exchange? As part of your answer, please indicate the character of any such gain or loss.

8. Assuming that an election is not made under Section 362(e)(2)(C), what is LossCos A/B in the building contributed by Allison (measured immediately after the exchange)?

Facts Applicable to Question 9: Keith and Mick are unrelated parties who contribute the following assets to a corporation (Corp) as part of an integrated transaction in exchange for 100% of Corps stock: (i) Keith contributes land constituting Section 1231 property with FMV of $700,000 and A/B of $100,000 in exchange for 700 shares (representing 70% of Corps stock); and (ii) Mick contributes inventory (held for sale to customers in the ordinary course of a trade or business) with FMV of $300,000 and A/B of $200,000 in exchange for 300 shares (representing 30% of Corps stock). Corp has a single class of common stock. As part of a prearranged binding agreement entered into concurrently with Keith and Micks contributions of property to Corp, Keith sells 400 of his 700 shares to Charlie for $400,000 cash that Charlie pays to Keith (i.e., Charlie does not contribute any property to Corp). As a result, after all of the foregoing steps have been concluded, Keith owns 300 shares (representing 30% of the stock), Mick owns 300 shares (representing 30% of the stock), and Charlie owns 400 shares (representing 40% of the stock). 9. How much gain (if any) is recognized by Mick upon the exchange? As part of your answer, please indicate the character of any such gain.

Facts Applicable to Question 10: Paul and Ringo are unrelated parties owning the following assets: a.Paul owns land (BlackAcre) with FMV of $7,000,000 and A/B of $1,000,000. The land is a capital asset with a long-term holding period in Pauls hands. b.Ringo owns land (WhiteAcre) with FMV of $1,000,000 and A/B of $300,000. The land is a capital asset with a long-term holding period in Ringos hands. Paul contributes BlackAcre to a corporation (DevCo) in exchange for 700 shares of DevCo stock (representing 70% of DevCos stock). Ringo enters into an employment agreement with DevCo. In accordance with Ringos employment agreement, and as part of a prearranged binding agreement entered into concurrently with Pauls contribution of BlackAcre to DevCo, Ringo receives (i) 100 shares of DevCo stock with an assumed FMV of $1,000,000 (representing 10% of DevCos stock) in exchange for Ringos contribution of WhiteAcre, and (ii) 200 shares of DevCo stock with an assumed FMV of $2,000,000 (representing 20% of DevCos stock) in connection with Ringos agreement to perform future services for DevCo. Assume that DevCo has a single class of common stock and that the shares received by Ringo are not subject to a substantial risk of forfeiture within the meaning of Section 83. 10. How much income or gain (if any) is recognized by Ringo with respect to his receipt of 300 shares of DevCo stock? As part of your answer, please indicate the character of any such income or gain.