d.    What is the corporation’s adjusted basis in each of the assets received in the exchange? e. Would the stock held by Jeff qualify as §1244 stock?  Why is this determination important to Jeff?

SWFT Corp Partner Estates Trusts
42nd Edition
ISBN:9780357161548
Author:Raabe
Publisher:Raabe
Chapter7: Corporations: Reorganizations
Section: Chapter Questions
Problem 23P
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ONLY SOLVE PART D and E

Jeff Stein incorporated his sole proprietorship by transferring inventory, a building, and land to the corporation in return for 100 percent of the corporation’s stock.  The property transferred to the corporation had the following fair market value and adjusted bases.

 

FMV

Adjusted Basis

Inventory

$30,000

$45,000

Building

150,000

120,000

Land

180,000

90,000

Total

$360,000

$255,000

The fair market value of the corporation’s stock received in the exchange equaled the fair market value of the assets transferred to the corporation by Jeff.  The transaction met the requirements to be tax-deferred under §351.

a.     What amount of gain or loss does Jeff realize on the transfer of the property to his corporation?

b.    What amount of gain or loss does Jeff recognize on the transfer of the property to her corporation?

c.     What is Jeff’s basis in the stock he receives in his corporation?

d.    What is the corporation’s adjusted basis in each of the assets received in the exchange?

e. Would the stock held by Jeff qualify as §1244 stock?  Why is this determination important to Jeff?

 

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