Question: Citron enters into a Type C restructuring with Ecru. Ecru transfers $800,000 of its voting stock for Citron's $1.2 million assets (basis $600,000) and $400,000
Citron enters into a "Type C" restructuring with Ecru. Ecru transfers $800,000 of its voting stock for Citron's $1.2 million assets (basis $600,000) and $400,000 liabilities. Citron retains one asset, land, which it distributes to its sole individual shareholder, Electra. The land is valued at $130,000, and its basis is $80,000. Electra's basis in her Citron stock is $970,000.
Determine the income tax consequences for Citron, Ecru, and Electra, including Ecru's basis in the assets it receives from Citron and Electra's basis in the Ecru stock she receives.
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