Joe, Karen, and Larry form Gray Corporation. Joe contributes land (a capital asset) having an $8,000 adjusted basis and a $15,000 FMV to Gray in exchange for Gray ten-year notes having a $15,000 face value. Karen contributes equipment (Sec. 1231 property) having an $18,000 adjusted basis and a $25,000 FMV for 50 shares of Gray stock. She previously claimed $10,000 of depreciation on the equipment. Larry contributes $25,000 cash for 50 shares of Gray stock.
a. What are the amount and character of Joe’s, Karen’s, and Larry’s recognized gains or losses?
b. What basis do Joe, Karen, and Larry take in the stock or notes they receive?
c. What basis does Gray take in the land and equipment? What happens to the $10,000 of depreciation recapture potential on the equipment?