Question
The stock of QRS Corp is owned 60% by Gold Corporation, 30% by Copper Corp, a wholly owned subsidiary of Gold Corporation, and 10% by
The stock of QRS Corp is owned 60% by Gold Corporation, 30% by Copper Corp, a wholly owned subsidiary of Gold Corporation, and 10% by Jill Greene. As of June 30, 2019, QRS Corp had the following assets:
Adjusted Basis FMV
Cash $ 40,000 $ 40,000
Equipment 64,000 106,000
Land 94,000 80,000
Verizon stock 50,000 74,000
Gold Corporation acquired its stock in 1995 paying $97,000 for it, Copper Corp acquired its stock in 1999 paying $58,000 for it and Greene acquired her stock in 2009 paying $43,000 for it. QRS Corp did not acquire any of its assets in the prior five years.
On June 30, 2019, QRS Corp. adopts a plan of liquidation and immediately distributes its assets to Gold Corporation, Copper Corp and Greene. Gold Corporation receives the Equipment and Verizon stock, Copper Corp receives the Land and $10,000 of cash and Greene receives $30,000 of cash.
A. What is the amount of gain or loss to be recognized by Gold Corporation, Copper Corp and Greene as a result of their receipt of the assets of QRS Corp?
B. What is the amount of gain or loss to be recognized by QRS Corp as a result of the distribution of its assets to Gold Corporation, Copper Corp and Greene?
C. What is Gold Corporations basis in the Equipment and Verizon stock it receives?
D. What is Copper Corps basis in the Land stock it receives?
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