Question

Please use the following fact pattern to answer THE questions Assume no elections are made and that the general Internal Revenue Rules apply. An individual contributes three properties to a corporation in a 351 exchange. The first property has a basis of $50000, and fair market value of $10000. The second property has a basis of $100000, and fair market value of $85000. The third property has a basis of $70000, and fair market value of $80000.

1. The individual's stock basis after the transfer is:

A. 220000

B. 0

C. 175000

D. 200000

E. A and C only

F. None of the above

2. What is the corporation's basis in property 1 after the transfer (rounded to nearest whole number)

A. $17273

B. $12944

C. $32727

D. $50000

E. $10,000

F. None of the above

3. What is the corporation's basis in property 2 after the transfer? (rounded to nearest whole number)

A. $100000

B. $15723

C. $85000

D. $87727

E. None of the above

4. What is the corporation’s basis in property 3 after the transfer? (rounded to nearest whole number)

A. $80000

B. $9877

C. $3984

D. $70000

E. None of the above

Answer 1

Issuance of stock in exchange for property is a non taxable transaction under section 351 only if all the contributors of cash + propertry have 80% or more control.

Shareholder's basis for stock = Carryover basis - Mortgage debt (if any)

Corporation's basis = Carryover basis

If the carryover basis of the property is greater than the Fair market value of the property,

Shareholder's basis = Carryover basis - Mortgage debt (if any)

Corporation's basis = Carryover basis - Excess basis over Fair market value = Fair market value

1.

Individual's stock basis after the transfer = 50,000 + 100,000 + 70,000 = 220,000

2.

Corporation's basis in property 1 after the transfer = 10,000 (fair market value)

3.

Corporation's basis in property 2 after the transfer = 85,000 (fair market value)

4.

Corporation's basis in property 3 after the transfer = 70,000 (carryover basis)