A, B, and C form X Corporation by transferring the following assets, each of which has been
Question:
A, B, and C form X Corporation by transferring the following assets, each of which has been held long-term:
Transferor Asset Adj. Basis F.M.V.
A Equipment (all § 1245 gain) $15,000 $22,000
B Inventory $7,000 $20,000
Land $13,000 $10,000
C Land $20,000 $50,000
In exchange, A receives 15 shares of X common stock (value -- $15,000), $2,000 cash and 100 shares of X preferred stock (value -- $5,000), B receives 15 shares of X common stock (value - $15,000) and $15,000 cash, and C receives 10 shares of X common stock (value -- $10,000), $5,000 cash and X's note for $35,000, payable in two years. None of the transferors is a "dealer" in real estate. Assume that the preferred stock issued to A is not "nonqualified preferred stock."
(a) What are the tax consequences (gain or loss realized and recognized, basis and holding period) of the transfers described above to each shareholder and to X Corporation?
(b) What result to C in (a) above, if instead of land, C transferred depreciable equipment with the same adjusted basis and fair market value as the land and an original cost to C of $50,000? See § 453 (i)