Question

Arte, an individual, wants to transfer raw land worth $100,000 with a $50,000 basis to Angel...

  1. Arte, an individual, wants to transfer raw land worth $100,000 with a $50,000 basis to Angel Corporation for $100,000 in value. How much income will Arte realize and recognize if he receives $100,000 cash from Angel Corporation, and what will be Angel Corporation’s basis in the land? Does Arte’s income recognition change if Angel Corporation transfers its own stock to Arte in the exchange (assume the “general rule” applies)? Will the answer change in the stock case if Arte is the sole shareholder of Angel Corporation? Conceptually, why should it change?

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