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Your clients, Ting and Mae, plan to form Carolina Construction Company (CCC) and prefer the formation be tax-deferred. Ting plans to transfer only property
Your clients, Ting and Mae, plan to form Carolina Construction Company (CCC) and prefer the formation be tax-deferred. Ting plans to transfer only property in the proposed transfer. Ting's ownership interest is 75%. Mae plans to transfer only services in the proposed transfer, but also has some property she could transfer. Mae's ownership interest is 25%. Below are FMV and A.B. for their property and services. You should assume the FMV of the corporation's stock equals the FMV of the assets you advise your clients to contribute in the tax-deferred transfer (i.e., there is no boot received in the transfer). Any other assumptions are your own and you should state those (i.e.. preface with) before providing your answer. Transferor Property/Services FMV A.B. Ting Building subject to mortgage of $100,000 $250,000 $205,000 Dump Truck $80,000 $125,000 Excavator $105,000 $75,000 Backhoe $95,000 $80,000 Mae Services $85,000 $85,000 New, state-of-art office copier/collater/fax/scan $8,500 $8,500 New laptop computer $1,900 $1,900 Answer the following questions: 1) What property, if any, do you advise your clients to transfer to the corporation? Be sure to explain your rationale (i.e.. why do you recommend this) and state any assumptions you've made. 2) Does Ting recognize any gain (loss) in the transfer? 3) What is Ting's stock basis after the transfer? 4) Does Mae recognize any gain (loss) in the transfer? 5) What is Mae's stock basis after the transfer? 6) What is the corporation's basis in the assets received?
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