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PROBLEM A, B and C form X Corporation by transferring the following assets, each of which has been held long-term: Transferor A B Asset Equipment

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PROBLEM A, B and C form X Corporation by transferring the following assets, each of which has been held long-term: Transferor A B Asset Equipment (all 1245 gain) Inventory Land Land Adj. Basis $15,000 $ 7,000 $13,000 $20,000 F.M.V. $22,000 $20,000 $10,000 $50,000 In exchange, A receives 15 shares of X common stock (value $15,000), $2,000 cash and 100 shares of X preferred stock (value-$5,000), B receives 15 shares of X common stock (value-$15,000) and $15,000 cash, and C receives 10 shares of X common stock (value-$10,000), $5,000 cash and X's note for $35,000, payable in two years. None of the transferors is a "dealer in real estate. Assume that the preferred stock issued to A is not "nonqualified preferred stock." (a) What are the tax consequences (gain or loss realized and recognized, basis and holding period) of the transfers described above to each shareholder and to X Corporation? (b) What result to C in (a), above, if instead of land, C transferred depreciable equipment with the same adjusted basis and fair market value as the land and an original cost to C of $50,000? See $ 453(i)

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