In forming Parts Incorporated as a corporation, Candice transferred inventory to Parts Incorporated in exchange for 30 percent of the corporation's stock (60 shares valued at $130,000). The inventorys fair market value was $147,000 and its tax basis to Candice was $75,000. The inventory was subject to a $17,000 liability that Parts Incorporated assumed on the transfer. Candice borrowed the $17,000 from the bank (using the inventory as collateral) shortly before transferring the inventory to Parts Incorporated and used the loan proceeds to pay for a family vacation to Europe.

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Assuming the transfer qualifies under 351 and that the liability has a tax-avoidance purpose, what gain or loss will Candice recognize on the transfer?

Assuming the original facts, what is Candice's basis in the stock received in the exchange?

Suppose the liability does not have a tax-avoidance purpose. What gain will Candice recognize on the transfer?

Suppose the liability does not have a tax-avoidance purpose, what is Candice's basis in the stock received in the exchange?