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Ms. Aldo contributed an office building to Aldo Home Furnishings and Design, a C corporation, in exchange for 30 percent equity interest in the business.

Ms. Aldo contributed an office building to Aldo Home Furnishings and Design, a C corporation, in exchange for 30 percent equity interest in the business. The company uses the building to house inventory and office space.

  • After the contribution, Ms. Aldo has an 80% interest in the corporation.
  • Her tax basis in the office building was $800,000 (building $500,000 and $300,000 land) and the building’s appraised FMV on date of contribution to the business was $1,000,000.

Ten years later, Ms. Aldo decided to retire on the last day of the year. The corporation sold the building to an unrelated purchaser for $1,500,000. A realtor was paid a 5 percent commission. The corporation will liquidate inventory shortly and the company may need your assistance at a later date.

Based on the factors above, did Ms. Aldo recognize a gain on the contribution of the office building to the corporation? Hint, use IRC Section 351 and other IRC sections in your analysis to explain your answer. Explain, be specific and concise.

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