Mickey, Mickayla, and Taylor are starting a new business (MMT). To get the business started, Mickey is contributing $228,000 for a 40 percent ownership interest, Mickayla is contributing a building with a value of $228,000 and a tax basis of $171,000 for a 40 percent ownership interest, and Taylor is contributing legal services for a 20 percent ownership interest.
What amount of gain is each owner required to recognize under each
of the following alternative situations? [Hint: Look at
§351 and §721.]
a. MMT is formed as a C corporation
b. MMT is formed as an S corporation.
c. MMT is formed as a LLC.
Ans A If it is a C corporation | ||||
Mickey | $0 | |||
Mickayla | $0 | |||
Taylor | $114,000.0 | |||
As per section 351 Mickey and Mickayla mwill not recognize any gain | ||||
As they transferred the asset. Taylor contributed services hence would | ||||
recognize gain | ||||
Taylor gain | ||||
Capital | ||||
Mickey | $228,000 | |||
Mickayla | $228,000 | 1 | ||
This is 80% capital | $456,000 | |||
Total capital 456000/.8 | $570,000.0 | |||
Taylor share | 20% | |||
Taylor capital | $114,000.0 | |||
Ans b If it is a S corporation | ||||
Mickey | $0 | |||
Mickayla | $0 | |||
Taylor | $114,000.0 | |||
ans c If its LLC | ||||
Mickey | $0 | |||
Mickayla | $0 | |||
Taylor | $114,000.0 | |||
If any doubt please comment. If satisfied you | ||||
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