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Tax related homework questions

Customer Question

I have some tax related homework questions. Can anyone help?

Submitted: 11 years ago.
Category: Tax
Customer: replied 11 years ago.

Assumptions: Except as otherwise stated, A starts out with non-depreciable real property (a capital asset) worth $100 (adjusted basis $40) and ends up with cash of $50 plus a 50% interest worth $50 in X, a newly organized corporation that owns the property.

In each problem, determine the following:

1. A’s amount realized
2. A’s gain or loss realized
3. A’s gain or loss recognized and the character thereof
4. A’s basis in the X stock received
5. A’s holding period for the X stock received (tacked or not?)
6. X’s basis in the property received
7. X’s holding period for the property received (tacked or not?)
8. The amount and character of X’s gain if X immediately sells the property for $100

#1) A transfers the property to X in exchange for all of X’s stock. Shortly thereafter, A sells half of his X stock to B for $50 and either

a) The stock sale is a “separate” event from the prior incorporation transaction; or
b) The stock sale is an integral part of the incorporation plan

Would the results be different if X made an S election? What if the basis for A’s property were $200 rather than $40?

#2) A sells a half interest in the property to B for $50. A and B then jointly transfer their property interests to X in exchange for X’s stock.

#3) A and B jointly organize X. A transfers his property to X in exchange for $50 in cash and half of X’s stock. B transfers $50 in cash to X in exchange for the other half of X’s stock.

#4) What would result in (3) above if A received $50 in five-year notes instead of cash? Assume the notes are debt and not equity.

#5) What would result in 1(a) above if A receives only “pure preferred” stock of X that is required to be redeemed in 5 years for $100?

#6) A borrows $50 from L (nonrecourse) on the security of the property. Shortly thereafter, A transfers the property to X (subject to this debt) in exchange for half of X’s stock, and B transfers $50 in cash to X in exchange for the other half of X’s stock. X subsequently uses the $50 cash to repay L.

#7) Same as (6) but the debt is recourse as to A and X does not assume it and A receives 100 shares and B receives 50 shares.

#8) A transfers $100 in uncollected customer accounts receivable (from A’s cash-basis service business) to X in exchange for half of X’s common stock plus X’s assumption of $50 of accounts payable attributable to the service business (which $50 A could have deducted upon payment in cash). B transfers $50 in cash to X in exchange for the other half of X’s stock. X uses this cash to pay off the assumed accounts payable.

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