Tri Corporation and Angle Corporation are combining to form Triangle Corporation in a restructuring that qualifies as “Type A” consolidation reorganization. Tyron, the sole shareholder of Tri, has a basis of $250,000 in his stock, which he purchased 10 years ago. Anna, the sole shareholder of Angle, also has a basis of $250,000 in her stock. She purchased the stock four months ago. Tri transfers all of its assets valued at $650,000 (adjusted basis of $280,000) and $250,000 in liabilities to Triangle for $50,000 in cash and $350,000 in Triangle stock. Angle transfers all of its assets valued at $250,000 (adjusted basis of $200,000) and $50,000 in liabilities to Triangle for $30,000 in cash and $170,000 in Triangle stock. Upon completion of the consolidation, the Triangle stock and cash are transferred to Tyron and Anna, and both Tri and Angle cease to exist by operation of law. Determine the gain or loss that Tri, Angle, Tyron, Anna, and Triangle recognize from the reorganization. What are Triangle’s bases in the assets it receives and Tyron’s and Anna’s new bases in their Triangle stock?
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