Question
Z owns a rental building (its only asset) with a gross fair market value of $5,000 subject to the non-recourse mortgage of $2,000. Zs adjusted
Z owns a rental building (its only asset) with a gross fair market value of $5,000 subject to the non-recourse mortgage of $2,000. Zs adjusted basis for this building is $1,500. All of Zs stock is owned by C, whose basis for his stock in Z is $500. Z had 1,000 of E&P. Z is on the accrual method of accounting and reports on the calendar year. Assume that the corporate tax payable by Z on $3,500 gained is $1,250 and on $3,000 gained is $1,000. Z sells the building, subject to the mortgage, to D in the current year for $3,000 in cash. Z then liquidates, distributing all of the cash (remaining after paying its taxes) to C in cancellation of Cs stock in the current year. Same facts as above, except that Z adopts a plan of complete liquidation instead of selling the building to D. Z distributes the building to C in-kind pursuant to the plan. C then sells the building to D for $3,000 in cash with D taking subject to the mortgage of $2,000. Same facts as above, except that Z is an S Corporation and Section 1374 does not apply.
a. Z has $1,500 gain.
b. C has a $2,500 gain on the distribution.
c. C has a $1,000 ordinary loss on the distribution under Section 1244 if that section applies.
d. C has $1,000 capital loss. e. None of the above.
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