Ivan incorporated his sole proprietorship by transferring inventory, a building, and land to the corporation in return for 100 percent of the corporation's stock. The property transferred to the corporation had the following fair market value and adjusted basis.
_________________________________FMV___________Adjusted Basis
Inventory........$ 10,000..........................$15,000
Building.............50,000...........................40,000
Land.................60,000...........................30,000
Total.............$ 120,000.........................$ 85,000
The fair market value of the corporation's stock received in the exchange equaled the fair market value of the assets transferred to the corporation by Ivan. The transaction met the requirements to be tax-deferred under §351.
a. What amount of gain or loss does Ivan realize on the transfer of the property to his corporation?
b. What amount of gain or loss does Ivan recognize on the transfer of the property to her corporation?
c. What is Ivan's basis in the stock he receives in his corporation?
d. What is the corporation's adjusted basis in each of the assets received in the exchange?
e. Would the stock held by Ivan qualify as §1244 stock? Why would this fact be important if he sold his stock at a loss at some future date?