Mary and Todd form the MT Corporation, with a transfer of the following properties:
Mary $500,000 cash
Todd $500,000 FMV property
$300,000 tax basis
Both Mary and Todd receive a 50% interest in the corporate stock.
Complete the following blanks:
Mary Todd
Realized gain ________ ________
Recognized gain ________ _________
Basis of stock _________ _________
MT basis in contributed asset _________ _________
VARIATION 1: In addition to Mary and Todd, Karla joins the corporation at its inception. Karla will provide services to the corporation in exchange for a 25% interest in the stock. That is, she receives 25% of the outstanding shares. Does anything change? Why or why not?
VARIATION 2: return to original facts (no Karla). Todd’s property is valued at $700,000 but is contributed subject to a $200,000 liability.
Complete the following blanks
Mary Todd
Realized gain ________ ________
Recognized gain ________ _________
Basis of stock _________ _________
MT basis in contributed asset _________ _________
Variation 1
there is no change in the professional service and scenario provided by Karla and it will be ordinary income.
Variation 2
As per the tax rules, when a person contributes a property in partnership and gets a share in the partnership, he/she is not required to realize any gains.
- since he has not sold the property,
- hence, no gain for mary & todd.
Mary & Todd's decrease in liability = $200,000 * 20% = $100,000
Mary & Todd's basis in the partnership = $500,000 - $ 100,000 = $400,000
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