Question

Your client, Abbad, is contemplating the contribution of property to a “C” corporation in exchange for that corporation’s common stock. Abbad is considering the contribution of one of two raw parcels of land he owns, Parcel 1 and Parcel 2. Neither parcel has any improvements. The corporation would like either of these parcels to locate its new manufacturing plant. Parcel 1 has an adjusted tax basis of $550,000 to Abbad and a fair value of $1.5 million. Parcel 2 has an adjusted tax basis of $1.8 million to Abbad and a fair value of $1.5 million. Parcel 2 has decreased in value due to the fact that a small portion of it is now considered wetlands. However, this would not impact the construction of the new manufacturing plant. In exchange for either of these two parcels, the corporation will transfer only voting shares of common stock to Abbad. After the transfer, Abbad will have 80% control of the corporation. Business valuators expect the corporation’s stock to significantly increase in value once the manufacturing plant is built. If Abbad wants to do this transfer, what would you suggest to him?
a. Transfer either parcel because it doesn’t make a difference
b. Transfer Parcel 1
c. Transfer Parcel 2
d. Consider transferring other property besides the land.

Answer 1

Answer to question

		in million
	Adjusted tax basi	Fair Value
Parcel 1	$                                   0.55	$1.5
Parcel 2	$                                   1.80	$1.5

Abbad will have 80% control of the corporation. Business valuators expect the corporation’s stock to significantly increase in value once the manufacturing plant is built.

So its better to transfer parcel 1 in which adjusted tax basis is lower comper to parcel 2 and fair value is same in both the option.