Turnip, Inc., a C corporation, distributes a tract of land held
as an investment (FMV =...
Turnip, Inc., a C corporation, distributes a tract of land held
as an investment (FMV = $82,000, basis = $22,000) to Chang, its
majority (60%) shareholder in exchange for all of his stock. The
land is subject to a liability of $100,000. Turnip, Inc. has
accumulated E & P of $50,000 and a marginal tax rate of 21%.
Chang’s basis in his Turnip’s stock is $20,000 and has an
individual marginal tax rate of 32%, a long-term capital gains tax...
1. Turnip, Inc., a C corporation, distributes a tract of land
held as an investment (FMV...
1. Turnip, Inc., a C corporation, distributes a tract of land
held as an investment (FMV = $82,000, basis = $22,000) to Chang,
its majority (60%) shareholder in exchange for all of his stock.
Turnip, Inc. has accumulated E & P of $50,000 and a marginal
tax rate of 21%. Chang’s basis in his Turnip’s stock is $20,000 and
has an individual marginal tax rate of 32%, a long-term capital
gains tax rate of 15%, and $100,000 of other long-term...
Turnip, Inc,. an S corporation, distributes a tract of land held
as an investment (FMV=$82,000, basis=$22,000)...
Turnip, Inc,. an S corporation, distributes a tract of land held
as an investment (FMV=$82,000, basis=$22,000) to chang, its sole
shareholder. An AAA bypass election was not made. Turnip, Inc. has
an AAA balance of $10,000 an OAA balance of $15,000, a PTI balance
of $5,000 and an AEP balanc eof $20,000. CHang's basis in his
Turnip's stock is $20,000, has and individual marginal tax rate of
33% and a capital gains tax rate of 15%.
What is Turnip's recognized...
In a liquidating distribution, Ryan Inc distributes land to its
shareholders. Ryan Inc acquired the land...
In a liquidating distribution, Ryan Inc distributes land to its
shareholders. Ryan Inc acquired the land 3 years ago in a §351
transfer. Ryan Inc distributes land with FMV of $1,800,000,
adjusted basis of $400,000 pro-rata to its two individual
shareholders Adama and Brent. Adam and Brent do not get along and
are not related to each other. Adam (80%) owner has stock basis of
$87,000. Brent (20%) owner has stock basis of $20,000.
a. What is the tax result...
Kion and Simba formed Lion Inc., a C-Corporation. Kion transfers
land (FMV 650,000 and adjusted basis...
Kion and Simba formed Lion Inc., a C-Corporation. Kion transfers
land (FMV 650,000 and adjusted basis of $350,000) for 50% of the
stock in the corporation. Simba transfers equipment (FMV 350,000
adjusted basis of $200,000) and will provide management services
worth $250,000 after Lion Inc. opens for business for 50% of the
stock in the corporation.
a. Will the transfer qualify under §351 as a tax free transfer?
Explain.
b. What are the tax consequences to Kion and Simba including...
3. Kevin and Lori formed Wonderful Inc., a C-Corporation. Kevin
transfers land (FMV $250,000 and adjusted...
3. Kevin and Lori formed Wonderful Inc., a C-Corporation. Kevin
transfers land (FMV $250,000 and adjusted basis of 90,000) for 50%
of the stock in the corporation and $20,000 cash. Lori transfers
equipment (FMV 30,000 adjusted basis of $5,000) and will provide
management services worth $200,000 after Wonderful Inc. opens for
50% of the stock in the corporation. (7 points) a. Will the
transfer qualify under §351 as a tax free transfer? Explain. b.
What are the tax consequences to...
Suppose Joe contributes land (basis = $40,000, FMV = $50,000) to
a partnership in exchange for...
Suppose Joe contributes land (basis = $40,000, FMV = $50,000) to
a partnership in exchange for a partnership interest and three
years later the partnership distributes the land to Susan (at the
time of the distribution the land’s basis = $40,000, and FMV =
$70,000). The land is a capital asset to Joe and the partnership,
but an ordinary asset to Susan. Joe and Susan are both partners in
the partnership. If Joe owns 25% and Susan owns 60% of...
Jack Corporation is owned 75% by Sherri and 25% by Mark. Sherri
and Mark have
$125,000...
Jack Corporation is owned 75% by Sherri and 25% by Mark. Sherri
and Mark have
$125,000 and $50,000 bases in their stock, respectively. Jack
Corporation adopts a plan of
liquidation on March 1. On April 12, Sherri receives the
following property as a liquidating
distribution: cash of $30,000; land, $125,000 FMV; and 150
shares of Green Corporation
stock, $30,000 FMV. The land is subject to a $20,000 mortgage.
On the same date, Mark
receives $10,000 FMV of Green stock (50...
Sleeping Corporation makes a liquidating distribution to its
shareholder Ted. The liquidating distribution is land that...
Sleeping Corporation makes a liquidating distribution to its
shareholder Ted. The liquidating distribution is land that it
acquired in a §351 transfer two years ago. At the time of the
contribution the land had basis of $100,000 and FMV of
$500,000. At the time of distribution the FMV of
the land is $60,000. Ted owns 20% of the company, Stella owns 35%,
Marcus owns $25%, and Brady owns 20%. Stella is Ted’s grandmother.
Marcus and Brady are Ted’s best friends...
Copper Corporation (E&P of 1.2 million) distributes land
(basis of 300,000, fair market value of $700,000)...
Copper Corporation (E&P of 1.2 million) distributes land
(basis of 300,000, fair market value of $700,000) subject to a
900,000 liability to Lauren, a shareholder, to carry out a
qualitying stock redemption. Lauren has basis of 100,000 in the
shares redeemed. With regard to the redemption, what are the income
tax consequences to Lauren and Copper Corporation