Question
J owns all the stock of T. T's only asset is a thoroughbred racing track with an adjusted basis of $1,200,000 and a fair market
J owns all the stock of T. T's only asset is a thoroughbred racing track with an adjusted basis of $1,200,000 and a fair market value of $3,000,000. J's basis in the T stock is $1,000,000. P, a corporate developer of shopping malls wants to acquire the race track for a mall site. P and J agree on a Type C reorganization, with T trading the race track for P stock worth $2,580,000 and $20,000 in cash and then liquidating. P will give T some treasury shares P bought in the market for $2,000,000. Assume this will qualify as a good Type C reorganization to which T and P are "parties to a reorganization."
a. P recognizes gain on the transfer of the treasury stock because of Section 1032.
b. P takes a transferred basis from T of $1,200,000 plus $20,000 gain recognized under Section 362.
c. P takes a transferred basis from T of $1,200,000 under Section 362.
d. A and B.
e.A and C.
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