$2.$ Father had some land that he had purchased for $$100,000$ but which had increased in value to $$200,000.$ He transferred it to Daughter for $$100,000$ in cash in a transaction properly identified as in part of a gift and in part a sale. Assume no gift tax was paid on the transfer.

What gain to Father and what basis to Daughter under Reg$\mathrm{.}1\mathrm{.}1001-1($e$)$ and $1\mathrm{.}1015-4($a$)(1)?$

Suppose the transactions were viewed as a sale of one$-$half of the land for full consideration and an outright gift of the other one half. How would this affect Father$$s gain and Daughter$$s basis? Is it a more realistic view than that of the Regulations? Cf$.170($e$)(2)$ and $1011($b$),$ relating to bargain sales to charities.

Answer rating: 100% (QA)

Under Regulations 110011e and 110154a1 when a transfer of property occurs between related parties fo... View the full answer