Question
White Corporation owns a rental building (its only asset) with a gross FMV of $1,000, subject to a nonrecourse mortgage of $400. White's adjusted basis
White Corporation owns a rental building (its only asset) with a gross FMV of $1,000, subject to a nonrecourse mortgage of $400. White's adjusted basis for this building is $300.Abby owns all of White's stock, with a total basis of $100. Whitehas $200 of E&P. White is on the accrual method of accounting and reports on the calendar year. Assume that the corporate tax payable by White on $700 gain is $250 and on $600 gain is $200. For each of the following problems below, determine the amounts and character of realized and recognized gain or loss to all parties, the time of recognition, and the transferee's basis in any property received in kind.
Mix Corporation pays $300 cash and gives a Mix Corporation $300 note payable in equal annual installments over five years. White's plan of liquidation provides that White will stay in existence for five years for the sole purpose of collecting the note and paying the net amount over to Abby annually.Change problem because of sec 453 12 month rule for liquidations or add facts so students don't go to this rule.
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