Question
Tesla, Inc., is a calendar year, accrual basis corporation with Elon as its sole shareholder (basis in his stock is $90,000). On January 1 of
Tesla, Inc., is a calendar year, accrual basis corporation with Elon as its sole shareholder (basis in his stock is $90,000). On January 1 of the current year, Tesla has accumulated E & P of $200,000. Before considering the effect of the distribution described below, the corporations current E P is $50,000. On November 1, Tesla distributes an office building to Elon. The office building has an adjusted basis of $80,000 (fair market value of $100,000) and is subject to a mortgage of $90,000. Assume that the building has been depreciated using the ADS method for both income tax and E&P purposes. What are the tax consequences of the distribution to Tesla and to Elon? (In your answer, be sure to describe the effects on taxable income for both Tesla and Elon, the impact of the distribution on Teslas E&P, and Elons basis in the building.)
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