$1.$ Complete the following schedule $($see excel$)$ for each case. Unless otherwise indicated, assume that the shareholders have ample basis in the stock investment. There are $10$ specific answers.

$2.$ Crow Corporation $($a calendar year, accrual basis taxpayer$)$ had the following transactions in $2024,$ its second year of operation:

Taxable income $($after considering all of the below items$)$ $$405,000$

Federal income tax liability paid net of credits $92,500$

Tax$-$exempt interest income $8,000$

Meals expense in total $($use $50\%$ disallowance rule$)4,000$

Premiums paid on key employee life insurance $9,500$

Excess of capital losses over capital gains $13,000$

MACRS deduction $26,000$

Straight$-$line depreciation using ADS lives $16,000$

Net Operating Loss from prior year used this year. $28,000.$

Compute Crow$$s current E & P$.$

$3.$ Rhonda owns $50\%$ of the stock of Peach Corporation. She and the other $50\%$ shareholder, Rachel, have decided that additional contributions of capital are needed if Peach is to remain successful in its competitive industry. The two shareholders have agreed that Rhonda will contribute assets having a value of $$70,000($adjusted basis of $$12,000)$ in exchange for additional shares of stock. After the transaction, Rhonda will hold $70\%$ of Peach Corporation and Rachel$$s interest will fall to $30\%.$

a$.$ What gain is realized on the transaction?

b$.$ How much of the gain will be recognized?

$4.$ Adam transfers property with an adjusted basis of $$30,000$ and a fair market value of $$90,000$ to Swift Corporation for $100\%$ of the stock. The property is subject to a liability of $$55,000,$ which Swift assumes.

a$.$ What Internal Revenue Code Section over$-$rides the general non$-$recognition rule of IRC $351?$

b$.$ What is the basis of the Swift stock to Adam?

c$.$ What is the basis of the property to Swift Corporation?

$5.$ Orange Corporation has a wholly owned subsidiary, Green Corporation. Upon liquidation of Green pursuant to $332,$ Orange receives Green$$s only asset, a parcel of land worth $$400,000.$ Green Corporation had a basis of $$320,000$ in the land.

a$.$ What are the tax consequences of this land transfer to Green Corporation?

b$.$ What are the tax consequences to Orange Corporation?

$6.$ X Corporation makes a cash tender to the shareholders of Y Corporation for $100\%$ of the shares of Y Corporation.

a$.$ Will Y Corporation recognize a gain if Y Corporation shareholders$$ sell their shares for cash?

b$.$ Will X Corporation take a carryover basis in Y Corporation$$s assets, or will X Corporation be able to step$-$up the tax basis in assets to reflect the FMV of Y Corporation?

c$.$ Based on a$.$ will X Corporation record a deferred tax asset for the addi