Question
Last year, Pig Corporation acquired land and securities in a 351 tax-free exchange. On the date of the transfer, the land had a basis of
Last year, Pig Corporation acquired land and securities in a 351 tax-free exchange. On the date of the transfer, the land had a basis of $720,000 and a fair market value of $1 million, and the securities had a basis of $110,000 and a fair market value of $250,000. Pig Corporation has two shareholders, Mindy and Pete, who are unrelated. Mindy owns 85% of the stock in the corporation, and Pete owns 15%. Pig Corporation adopts a plan of liquidation in the current year. On this date, the value of the land has decreased to $500,000.
Now assume that the land had a fair market value of $630,000 on the date of its transfer to the corporation. On the date of liquidation, the land's fair market value has decreased to $500,000. Indicate how your answers to each of the above would change if Pig Corporation would:
A) Distribute all of the land to Mindy.
B)Distribute all of the land to Pete.
C) Distribute 85% of the land to Mindy and 15% to Pete.
D) Distribute 50% of the land to Mindy and 50% to Pete.
E) Sell the land and distribute the proceeds of $500,000 proportionately to Mindy and to Pete.
F) Now which option should be selected?
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