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Ver five years. transferred property would be to the corporation when the property is depreciable real estate with no lurking recapture gain. PROBLEM A, B

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Ver five years. transferred property would be to the corporation when the property is depreciable real estate with no lurking recapture gain. PROBLEM A, B and C form X Corporation by transferring the following assets, each of which has been held long-term: the the ment Transferor Asset A Equipment (all 1245 gain) Adj. Basis F.M.V. $15,000 B $22,000 Inventory $ 7,000 $20,000 Land $13,000 $10,000 Land $20,000 $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 nder acre) (the year ty is ed a the 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). of the n. For ed gain under

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