Assume the same basic facts as in Problem I:17-8. How would your answer change if the entity

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Assume the same basic facts as in Problem I:17-8. How would your answer change if the entity is a new corporation with all owners making property contributions? The corporation makes a timely election to be treated as an S corporation beginning with its first year.

In problem

Sally contributes farm machinery with a $150,000 FMV, a $125,000 basis, and a $50,000 note owed to the AB Bank to a new partnership in exchange for a 25% partnership interest. Total partnership liabilities after Sally’s contribution are $340,000. What gain or loss do Sally and the partnership recognize on the property contribution to the partnership? What is the partnership’s basis and holding period in the machinery? What is Sally’s basis in her partnership interest? How would your answers to this problem change (if at all) had Sally’s asset contribution instead been made to an existing corporation for a 25% stock interest?

Corporation
A Corporation is a legal form of business that is separate from its owner. In other words, a corporation is a business or organization formed by a group of people, and its right and liabilities separate from those of the individuals involved. It may...
Partnership
A legal form of business operation between two or more individuals who share management and profits. A Written agreement between two or more individuals who join as partners to form and carry on a for-profit business. Among other things, it states...
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Federal Taxation 2017 Individuals

ISBN: 9780134420868

30th Edition

Authors: Thomas R. Pope, Timothy J. Rupert, Kenneth E. Anderson

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