Question: In 2 0 2 3 , Mr . Mark Graber sells non - depreciable capital property to an existing corporation in which he is the

In 2023, Mr. Mark Graber sells non-depreciable capital property to an existing corporation in which he is the sole shareholder. The sale is made using the rollover provisions of ITA 85(1). The corporation has a calendar-based December 31 taxation year end. The property has an ACB of $342,000 and Mr. Graber believes that it has an FMV of $560,000. Reflecting this view, he takes back a promissory note with an FMV of $560,000 and one preferred share with a nominal value. He reports a taxable capital gain of $109,000[(1/2)($560,000- $342,000)] in his 2023 income tax return. In 2024, the CRA reassesses on the basis that the FMV of the property was only $475,000 at the time of the sale. Mr. Graber accepts this reassessed value and does not file an objection. There was no price adjustment clause (PAC) written into the purchase and sale agreement nor was there a valuation report prepared by an independent appraiser. Required: A. Determine the income tax consequences to Mr. Graber that will result from the sale of the property to the corporation in 2023 and the subsequent reassessment in 2024. B. Indicate the tax cost of the consideration received subsequent to the reassessment. Provide proper calculations.

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