Question
T Corp (T) has the following assets: Basis Value Tangible Properties (equipment, furniture, etc.) 30 20 Real Property 50 90 Total 80 110 T also
T Corp (T) has the following assets:
Basis | Value | |
Tangible Properties (equipment, furniture, etc.) | 30 | 20 |
Real Property | 50 | 90 |
Total | 80 | 110 |
T also has an account payable of $10 to David. T is wholly owned by Abby (basis $20; value $100). P Corp (P) and T propose to sign a binding contract pursuant to which T will transfer all of its assets and liabilities to P for the following alternative considerations. After the transfer, T will distribute all of its assets in a liquidation. Please determine if the following alternative considerations qualify as a C Reorganization.
(a) T transfers all of its assets and liabilities to P for $100 worth of Ps voting stock.
(b) T transfers all of its assets and liabilities to P for of Ps 20-year bonds with a face value of $100 and interest.
(c) T transfers all of its assets and liabilities to P for $100 worth of Ps preferred non-voting stock.
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