Week Two Problem Set
C: 2-8 What items are considered to be property for purposes of Sec. 351(a)? What items are not considered to be property?
Items that are considered property include all types of property, such as cash, accounts receivable, inventories, patents, installment obligations, equipment, and buildings. Services, certain debt of the corporation, and certain accrued interest on debt are not treated as property.
C: 2-43 Liabilities in Excess of Basis.
Barbara transfers $10,000 cash and machinery having a $15,000 basis and a $35,000 FMV to Moore Corporation in exchange for 50 shares of Moore stock. The machinery was used in Barbara’s business, originally cost Barbara $50,000, and is subject to a $28,000 liability, which Moore assumes. Sam exchanges $17,000 cash for the remaining 50 shares of Moore stock.
a. What are the amounts and character of Barbara’s recognized gain or loss?
According to section 351, the exchange is tax-free and no gain or loss can be recognized. Also, any property transferred to a corporation in exchange for stock cannot be recognized.
b. What is Barbara’s basis in the Moore stock?
($13,000)
c. What is Moore’s basis in the machinery?
$7,000
d. What are the amounts and character of Sam’s recognized gain or loss?
Sam recognizes a gain of $17,000 as this is now the Fair Market Value of his shares in Moore stock.
e. What is Sam’s basis in the Moore stock?
$17,000
f. When do Barbara and Sam’s holding periods for their stock begin?
The holding period begins the day after they purchase the stock.
g. How would your answers to Parts a through f change if Sam received $17,000 of Moore stock for legal services (instead of money)?
The answers would not change because stock purchase in exchange for services is treated the same as stock purchases in exchange for cash.
C: 2-45 Incorporating a Cash Basis Proprietorship.
Ted decides to incorporate his medical practice. He uses the cash method of accounting. On the date of incorporation, the practice
Items that are considered property include all types of property, such as cash, accounts receivable, inventories, patents, installment obligations, equipment, and buildings. Services, certain debt of the corporation, and certain accrued interest on debt are not treated as property.
C: 2-43 Liabilities in Excess of Basis.
Barbara transfers $10,000 cash and machinery having a $15,000 basis and a $35,000 FMV to Moore Corporation in exchange for 50 shares of Moore stock. The machinery was used in Barbara’s business, originally cost Barbara $50,000, and is subject to a $28,000 liability, which Moore assumes. Sam exchanges $17,000 cash for the remaining 50 shares of Moore stock.
a. What are the amounts and character of Barbara’s recognized gain or loss?
According to section 351, the exchange is tax-free and no gain or loss can be recognized. Also, any property transferred to a corporation in exchange for stock cannot be recognized.
b. What is Barbara’s basis in the Moore stock?
($13,000)
c. What is Moore’s basis in the machinery?
$7,000
d. What are the amounts and character of Sam’s recognized gain or loss?
Sam recognizes a gain of $17,000 as this is now the Fair Market Value of his shares in Moore stock.
e. What is Sam’s basis in the Moore stock?
$17,000
f. When do Barbara and Sam’s holding periods for their stock begin?
The holding period begins the day after they purchase the stock.
g. How would your answers to Parts a through f change if Sam received $17,000 of Moore stock for legal services (instead of money)?
The answers would not change because stock purchase in exchange for services is treated the same as stock purchases in exchange for cash.
C: 2-45 Incorporating a Cash Basis Proprietorship.
Ted decides to incorporate his medical practice. He uses the cash method of accounting. On the date of incorporation, the practice