Question
Two Individuals, Lionel and Merkin, were investigating the acquisition of a research business, the BLAND Corporation (a C corporation). As a part of their discussions
Two Individuals, Lionel and Merkin, were investigating the acquisition of a research business, the BLAND Corporation (a C corporation). As a part of their discussions with the sole shareholder of the corporation, Dr. Strangelove (an individual), they examined the company's tax accounting balance sheet. The relevant information is summarized as follows:
FMV
Cash 10,000
Receivables 15,000
Inventory 20,000
Building 100,000
Land 225,000
Total 370,000
Mortgage 112,000
Adjusted Basis
Cash 10,000
Receivables 15,000
Inventory 5,000
Building 50,000
Land 75,000
Total 155,000
Mortgage 112,000
Dr. Strangelove's tax basis in the BLAND stock is $100,000. Assume all corporations involved in this problem have lots of earnings and profits and have no NOL carryovers.
What amount of gain or loss does BLAND recognize if the transaction is structured as a direct asset sale to Lionel and Merkin, with Lionel and Merkin paying BLAND $400,000 in cash and assuming BLANDs $112,000 mortgage loan? [Note: Lionel and Merkin buy all of BLANDs assets (including the cash).]
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