Question

Sam and Devon agree to go into business together selling college-licensed clothing. According to the agreement, Sam will contribute inventory valued at $100,000 in return for 80 percent of the stock in the corporation. Sam’s tax basis in the inventory is $60,000. Devon will receive 20 percent of the stock in return for providing accounting services to the corporation (these qualify as organizational expenditures). The accounting services are valued at $25,000. (Negative amounts should be indicated by a minus sign. Leave no answer blank. Enter zero if applicable.)

Assume Devon received 25 percent of the stock in the corporation in return for his services.

f. What is Sam’s tax basis in the stock he receives in return for his contribution of property to the corporation?

g. What amount of income, gain, or loss does Devon recognize on the formation of the corporation? (Do not round intermediate calculations. Round your final answer to the nearest whole dollar amount.)

H.What is Devon’s tax basis in the stock he receives in return for his contribution of services to the corporation? (Do not round intermediate calculations. Round your final answer to the nearest whole dollar amount.)

Answer 1

f)

$100,000, equal to the fair market value of the inventory transferred.

g)

Devon has compensation income of $33,333. If Sam receives 75 percent of the stock in exchange for inventory worth $100,000, Devon’s services must be worth $33,333 ($100,000/.75 - $100,000). Devon is not entitled to tax deferral under §351 because services are not considered property.

h)

Devon’s tax basis in the stock he receives is $33,333, equal to the income recognized on the receipt of the stock in exchange for services.