Deck 4: Corporations: Organization and Capital Structure

Question 1

In order to retain the services of Eve,a key employee in Ted's sole proprietorship,Ted contracts with Eve to make her a 30% owner.Ted incorporates the business receiving in return 100% of the stock.Three days later,Ted transfers 30% of the stock to Eve.Under these circumstances,§ 351 will not apply to the incorporation of Ted's business.

Answer 1

True
In spite of Ted's momentary control,it will not suffice if such control is lost by a contractually binding prearranged agreement.

Question 2

The control requirement under § 351 requires that the person or persons transferring property to the corporation,immediately after the transfer,own stock possessing at least 80% of the total combined voting power of all classes of stock entitled to vote and at least 80% of the total number of shares of all other classes of stock of the corporation.

Answer 2

True

Question 3

The receipt of nonqualified preferred stock in exchange for the transfer of appreciated property to a controlled corporation results in recognition of gain to the transferor.

Answer 3

True
Nonqualified preferred stock,as well as securities (i.e.,long-term debt),constitute boot under § 351.Nonqualified preferred stock possesses many of the attributes of debt.

Question 4

Adam transfers inventory with an adjusted basis of $120,000,fair market value of $300,000,for 85% of the stock of Heron Corporation.In addition,he receives cash of $30,000.Adam recognizes a capital gain of $30,000 on the transfer.

Question 5

In a § 351 transfer,a shareholder receives boot of $10,000 but ends up with a realized loss of $3,000.Only $7,000 of the boot will be taxed to the shareholder.

Question 6

If a transaction qualifies under § 351,any recognized gain is equal to the value of the boot received.

Question 7

Eileen transfers property worth $200,000,basis of $60,000,to Goldfinch Corporation.In return,she receives 80% of the stock in Goldfinch Corporation worth $180,000,and a long-term note,executed by Goldfinch and made payable to Eileen,worth $20,000.Eileen will recognize no gain on the transfer.

Question 8

A person who performs services for a corporation in exchange for stock cannot be treated as a member of the transferring group even if that person also transfers some property to the corporation.

Question 9

For § 351 purposes,stock rights and stock warrants are included in the definition of "stock."

Question 10

In a § 351 transfer,a shareholder who receives boot has a realized loss.None of the boot is taxed.

Question 11

One month after Sally incorporates her sole proprietorship,she gives 25% of the stock to her children.Section 351 cannot apply to Sally because she has not satisfied the 80% control requirement.

Question 12

Gabriella and Juanita form Luster Corporation. Gabriella transfers cash of $50,000 for 50 shares of stock,while Juanita transfers a secret process (basis of zero; fair market value of $50,000)for 50 shares of stock. Neither Gabriella nor Juanita will recognize gain on the transfer.

Question 13

The definition of property for purposes of § 351 includes unrealized receivables transferred by a cash basis taxpayer.

Question 14

A transferor who receives stock for both property and services cannot be included in the control group in determining whether an exchange meets the requirements of § 351.

Question 15

Tina incorporates her sole proprietorship with assets having a fair market value of $100,000 and an adjusted basis of $110,000.Even though § 351 applies,Tina may recognize her realized loss of $10,000.

Question 16

Since services are not considered property under § 351,a taxpayer must report as income the fair market value of stock received for such services.

Question 17

Similar to like-kind exchanges,the receipt of "boot" under § 351 can cause gain to be recognized.

Question 18

A secret process and patentable inventory both constitute "property" under § 351. Consequently,neither gain nor loss is recognized on the transfer of such "property" to a controlled corporation.

Question 19

The reason for § 351 (which permits transfers to controlled corporations to be tax free)can be justified under the wherewithal to pay concept.

Question 20

The use of § 351 is not limited to the initial formation of a corporation,and it can apply to later transfers as well.

Question 21

When incorporating her sole proprietorship,Samantha transfers all of its assets and liabilities. Included in the $30,000 of liabilities assumed by the corporation is $500 that relates to a personal expenditure (not business related). Under these circumstances,the entire $30,000 will be treated as boot.

Question 22

Carmen and Carlos form White Corporation. Carmen transfers cash of $100,000 for 100 shares in White. Carlos transfers property (basis of $20,000 and fair market value of $80,000)and agrees to serve as manager of White Corporation for one year; in return,Carlos receives 100 shares in White. The value of Carlos's services is $20,000. White Corporation can deduct $20,000 as compensation expense for the value of the services Carlos will render.

Question 23

When depreciable property is transferred to a controlled corporation under § 351,any recapture potential disappears and does not carry over to the corporation.

Question 24

Kim,a real estate dealer,and others form Eagle Corporation under § 351.Kim contributes inventory (land held for resale)in return for Eagle stock.The holding period for the stock includes the holding period of the inventory.

Question 25

To ease a liquidity problem,all of the shareholders of Osprey Corporation contribute additional cash to its capital.Osprey has no tax consequences from the contribution.

Question 26

A shareholder transfers a capital asset to Red Corporation for its stock. If the transfer qualifies under § 351,Red's holding period for the asset begins on the day of the exchange.

Question 27

If both §§ 357(b)and (c)apply to the same transfer (i.e.,the liability is not supported by a bona fide business purpose and also exceeds the basis of the properties transferred),§ 357(b)predominates.

Question 28

When a taxpayer transfers property subject to a mortgage to a controlled corporation in an exchange qualifying under § 351,the transferor shareholder's basis in stock received in the transferee corporation is increased by the amount of the mortgage on the property.

Question 29

Rosa,the sole shareholder of Robin Corporation,contributes land (basis of $40,000 and fair market value of $100,000)to the corporation but does not receive additional stock. Neither Rosa nor Robin Corporation will have to recognize gain as a result of this transfer.

Question 30

If a corporation is thinly capitalized,all debt is reclassified as equity.

Question 31

In structuring the capitalization of a corporation,the tax law is neutral for the investor as to debt versus equity financings.

Question 32

A shareholder's holding period for stock received under § 351 includes the holding period of the property transferred to the corporation.

Question 33

Carl and Ben form Condor Corporation.Carl transfers cash of $50,000 for 50 shares of stock of Condor.Ben transfers a secret process with a tax basis of zero and a fair market value of $50,000 for the remaining 50 shares in Condor.Both Carl and Ben will have a tax basis of $50,000 in their stock in Condor Corporation.

Question 34

In a § 351 transaction,Gerald transfers equipment worth $85,000 (basis of $120,000)in exchange for all of the Rust Corporation stock. Gerald's stock basis is $120,000 and Rust's basis in the equipment is $120,000.

Question 35

In order to encourage the development of an industrial park,a county donates land to Ecru Corporation.The donation does not result in gross income to Ecru.

Question 36

All accounts payable of a cash basis taxpayer are included as liabilities under § 357(c)in determining whether liabilities exceed basis.

Question 37

Isabella and Marta form Pine Corporation. Isabella transfers land (basis of $40,000 and fair market value of $180,000)for 50 shares plus $20,000 cash,while Marta transfers $160,000 cash for the other 50 shares in Pine Corporation. Pine Corporation has a basis of $40,000 in the land it receives from Isabella.

Question 38

In determining whether § 357(c)applies,assess whether the liabilities involved exceed the bases of all assets a shareholder transfers to the corporation.

Question 39

Even if § 357(b)generates boot (i.e.,the liability is not supported by a bona fide business purpose),the transferor shareholder may not have to recognize gain.

Question 40

A city contributes $500,000 to a corporation as an inducement to locate in the city. Within the next 12 months,the corporation uses the money to purchase property. The corporation has income of $500,000 and must reduce its tax basis in the property by the same amount.

Question 41

Kim owns 100% of the stock of Cardinal Corporation.In the current year Kim transfers an installment obligation,tax basis of $30,000 and fair market value of $200,000,for additional stock in Cardinal worth $200,000.

A)Kim recognizes no taxable gain on the transfer.
B)Kim has a taxable gain of $170,000.
C)Kim has a taxable gain of $180,000.
D)Kim has a basis of $200,000 in the additional stock she received in Cardinal Corporation.
E)None of the above.

Question 42

Lucy and Marta form Blue Corporation. Lucy transfers land (basis of $40,000 and fair market value of $180,000)for 50 shares plus $20,000 cash. Marta transfers $160,000 cash for 50 shares in Blue Corporation.

A)Lucy's basis in the Blue Corporation stock is $40,000.
B)Blue Corporation's basis in the land is $40,000.
C)Blue Corporation's basis in the land is $180,000.
D)Lucy recognizes a gain on the transfer of $140,000.
E)None of the above.

Question 43

Mary transfers equipment (basis of $25,000 and fair market value of $120,000)to White Corporation. In return,Mary receives 80% of White Corporation's stock (worth $70,000)and an automobile (fair market value of $15,000). In addition,there is an outstanding mortgage of $35,000 (taken out 5 years ago)on the equipment,which White Corporation assumes. With respect to this transaction:

A)Mary's recognized gain is $25,000.
B)Mary's recognized gain is $10,000.
C)Mary has no recognized gain.
D)White Corporation's basis in the equipment is $25,000.
E)None of the above.

Question 44

Carl transfers land to Cardinal Corporation for 90% of the stock in Cardinal Corporation worth $20,000 plus a note payable to Carl in the amount of $40,000 and the assumption by Cardinal Corporation of a mortgage on the land in the amount of $100,000.The land,which has a basis to Carl of $70,000,is worth $160,000.

A)Carl will have a gain on the transfer of $70,000.
B)Carl will have a gain on the transfer of $30,000.
C)Cardinal Corporation will have a basis in the land transferred by Carl of $70,000.
D)Cardinal Corporation will have a basis in the land transferred by Carl of $160,000.
E)None of the above.

Question 45

Erica transfers land worth $500,000,basis of $100,000,to a newly formed corporation,Robin Corporation,for all of Robin's stock,worth $300,000,and a 10-year note.The note was executed by Robin and made payable to Erica in the amount of $200,000.As a result of the transfer:

A)Erica does not recognize gain.
B)Erica recognizes gain of $400,000.
C)Robin Corporation has a basis of $100,000 in the land.
D)Robin Corporation has a basis of $300,000 in the land.
E)None of the above.

Question 46

Dawn,a sole proprietor,was engaged in a service business and reported her income on a cash basis.Later,she incorporates her business and transfers the assets of the business to the corporation in return for all the stock in the corporation plus the corporation's assumption of the liabilities of her proprietorship.All the receivables and the unpaid trade payables are transferred to the newly formed corporation.The assets of the proprietorship had a basis of $105,000 and fair market value of $300,000.The trade accounts payable totaled $25,000.There was a note payable to the bank in the amount of $95,000 that the corporation assumes.The note was issued for the purchase of computers and other business equipment.

A)Dawn has a gain on the transfer of $15,000.
B)The basis of the assets to the corporation is $300,000.
C)Dawn has a basis of $10,000 in the stock she receives.
D)Dawn has a zero basis in the stock she receives.
E)None of the above.

Question 47

Hazel transferred the following assets to Starling Corporation.

In exchange,Hazel received 50% of Starling Corporation's only class of stock outstanding.The stock has no established value.However,all parties sincerely believe that the value of the stock Hazel received is the equivalent of the value of the assets she transferred.The only other shareholder,Rick,formed Starling Corporation five years ago.

A)Hazel has no gain or loss on the transfer.
B)Starling Corporation has a basis of $48,000 in the machinery and $108,000 in the land.
C)Starling Corporation has a basis of $36,000 in the machinery and $144,000 in the land.
D)Hazel has a basis of $276,000 in the stock of Starling Corporation.
E)None of the above.

Question 48

If a shareholder owns stock received as a gift from her mother,it cannot be § 1244 stock.

Question 49

A shareholder lends money to his corporation in his capacity as an investor.If the loans become worthless,a business bad debt results.

Question 50

Tara incorporates her sole proprietorship,transferring it to newly formed Black Corporation.The assets transferred have an adjusted basis of $240,000 and a fair market value of $300,000.Also transferred was $10,000 in liabilities,$1,000 of which was personal and the balance of $9,000 being business related.In return for these transfers,Tara receives all of the stock in Black Corporation.

A)Black Corporation has a basis of $241,000 in the property.
B)Black Corporation has a basis of $240,000 in the property.
C)Tara's basis in the Black Corporation stock is $241,000.
D)Tara's basis in the Black Corporation stock is $249,000.
E)None of the above.

Question 51

Tom and George form Swan Corporation with the following investments: Tom transfers machinery worth $100,000 (basis of $40,000),while George transfers land worth $90,000 (basis of $20,000)and services rendered in organizing the corporation worth $10,000.Each is issued 25 shares in Swan Corporation.With respect to the transfers:

A)Tom has no recognized gain; George recognizes gain of $80,000.
B)Neither Tom nor George recognizes gain.
C)Swan Corporation has a basis of $30,000 in the land.
D)George has a basis of $30,000 in the shares of Swan Corporation.
E)None of the above.

Question 52

Sarah and Tony (mother and son)form Dove Corporation with the following investments: cash by Sarah of $55,000; land by Tony (basis of $35,000 and fair market value of $45,000).Dove Corporation issues 200 shares of stock,100 each to Sarah and Tony.Thus,each receives stock in Dove worth $50,000.

A)Section 351 cannot apply since Sarah should have received 110 shares instead of only 100.
B)As a result of the transfer, Tony recognizes a gain of $10,000.
C)Tony's basis in the stock of Dove Corporation is $50,000.
D)Section 351 may apply because stock need not be issued to Sarah and Tony in proportion to the value of the property transferred.
E)None of the above.

Question 53

Rob and Sharon form Swallow Corporation with the following investments.

Each receives 50% of Swallow's stock.In addition,Sharon receives cash of $40,000.One result of these transfers is that Sharon has a:

A)Recognized loss of $60,000.
B)Recognized loss of $20,000.
C)Basis of $460,000 in the Swallow stock (assuming Swallow reduces its basis in the land to $440,000).
D)Basis of $400,000 in the Swallow stock (assuming Swallow reduces its basis in the land to $440,000).
E)None of the above.

Question 54

Mitchell and Lane form Green Corporation. Mitchell transfers property (basis of $105,000 and fair market value of $90,000)while Lane transfers land (basis of $8,000 and fair market value of $75,000)and $15,000 of cash. Each receives 50% of Green Corporation's stock (total value of $180,000). As a result of these transfers:

A)Mitchell has a recognized loss of $15,000, and Lane has a recognized gain of $67,000.
B)Neither Mitchell nor Lane has any recognized gain or loss.
C)Mitchell has no recognized loss, but Lane has a recognized gain of $15,000.
D)Green Corporation will have a basis in the land of $23,000.
E)None of the above.

Question 55

Amy owns 20% of the stock of Wren Corporation,which she acquired several years ago at a cost of $10,000.Amy is Vice-President of Wren and earns a salary of $80,000 annually.Last year,Wren Corporation was experiencing financial problems,and Amy loaned the corporation $25,000.In the current year,Wren becomes bankrupt,and both her stock investment and the loan become worthless.Amy has a nonbusiness bad debt deduction this year of $25,000.

Question 56

Paul,a cash basis taxpayer,incorporates his sole proprietorship.He transfers the following items to newly created Wren Corporation.

With respect to this transaction:

A)Wren Corporation's basis in the building is $120,000.
B)Paul has no recognized gain.
C)Paul has a recognized gain of $5,000.
D)Paul has a recognized gain of $10,000.
E)None of the above.

Question 57

Ann transferred land worth $200,000,with a tax basis of $40,000,to Brown Corporation,an existing entity,for 100 shares of its stock.Brown Corporation has two other shareholders,Bill and Bob,each of whom holds 100 shares.With respect to the transfer:

A)Ann has no recognized gain.
B)Brown Corporation has a basis of $160,000 in the land.
C)Ann has a basis of $200,000 in her 100 shares in Brown Corporation.
D)Ann has a basis of $40,000 in her 100 shares in Brown Corporation.
E)None of the above.

Question 58

Three individuals form Skylark Corporation with the following contributions: Cliff,cash of $50,000 for 50 shares; Brad,land worth $20,000 (basis of $11,000)for 20 shares; and Ron,cattle worth $9,000 (basis of $6,000)for 9 shares and services worth $21,000 for 21 shares.

A)These transfers are fully taxable and not subject to § 351.
B)Ron's basis in his stock is $27,000.
C)Ron's basis in his stock is $6,000.
D)Brad's basis in his stock is $20,000.
E)None of the above.

Question 59

Eve transfers property (basis of $120,000 and fair market value of $400,000)to Green Corporation for 80% of its stock (worth $350,000)and a long-term note (worth $50,000),executed by Green Corporation and made payable to Eve.As a result of the transfer:

A)Eve recognizes no gain.
B)Eve recognizes a gain of $230,000.
C)Eve recognizes a gain of $280,000.
D)Eve recognizes a gain of $50,000.
E)None of the above.

Question 60

Rick transferred the following assets and liabilities to Warbler Corporation.

In return Rick received $75,000 in cash plus 90% of Warbler Corporation's only class of stock outstanding (fair market value of $225,000).

A)Rick has a recognized gain of $60,000.
B)Rick has a recognized gain of $75,000.
C)Rick's basis in the stock of Warbler Corporation is $270,000.
D)Warbler Corporation has the same basis in the assets received as Rick does in the stock.
E)None of the above.

Question 61

Shawn,a sole proprietor,is engaged in a service business and uses the cash basis of accounting.In the current year,Shawn incorporates his business by forming Aqua Corporation.In exchange for all of its stock,Aqua receives: assets (basis of $380,000 and fair market value of $1.8 million),trade accounts payable of $125,000,and loan due to a bank of $375,000.The proceeds from the bank loan were used by Shawn to provide operating funds for the business.Aqua Corporation assumes all of the liabilities transferred to it.
a.Does Shawn recognize any gain on the incorporation? Explain.
b.What basis does Shawn have in the Aqua stock?
c.What basis does Aqua Corporation have in the assets it receives?

Question 62

Ashley,a 70% shareholder of Wren Corporation,transfers property with a basis of $250,000 and a fair market value of $900,000 to Wren Corporation for additional stock.Ashley owns 78% of Wren after the transfer.Two other shareholders in Wren transfer a nominal amount of property to Wren along with Ashley's transfer so that Ashley and the two shareholders own 90% of the Wren stock after the transfer.Does Ashley have taxable gain on the transfer?

Question 63

Four individuals form Chickadee Corporation under § 351.Two of these individuals,Jane and Walt,made the following contributions:

Both Jane and Walt receive stock in Chickadee Corporation equal to the value of their investments.

A)Jane must recognize income of $40,000; Walt has no income.
B)Neither Jane nor Walt recognize income.
C)Walt must recognize income of $130,000; Jane has no income.
D)Walt must recognize income of $100,000; Jane has no income.
E)None of the above.

Question 64

When Pheasant Corporation was formed under § 351,Kristen transferred property (basis of $26,000 and fair market value of $22,500)for § 1244 stock. Kristen's basis in the Pheasant stock is $26,000. Three years later,Pheasant Corporation goes bankrupt and its stock becomes worthless. Kristen,who is single,owned the stock as an investment. Kristen's loss is:

A)$26,000 capital.
B)$22,500 ordinary and $3,500 capital.
C)$3,500 ordinary and $22,500 capital.
D)$26,000 ordinary.
E)None of the above.

Question 65

Kirby and Helen form Red Corporation.Kirby transfers property,basis of $20,000 and value of $300,000,for 100 shares in Red Corporation.Helen transfers property,basis of $40,000 and value of $280,000,and provides legal services in organizing the corporation.The value of her services is $20,000.In return Helen receives 100 shares in Red Corporation.With respect to the transfers:

A)Kirby will recognize gain.
B)Helen will not recognize gain.
C)Red Corporation will have a basis of $280,000 in the property it acquired from Helen.
D)Red will have a business deduction of $20,000.
E)None of the above.

Question 66

Wren Corporation (a minority shareholder in Lark Corporation)has made loans to Lark Corporation that become worthless in the current year.

A)Wren Corporation is not permitted a deduction for the loans.
B)The loans result in a nonbusiness bad debt deduction to Wren Corporation.
C)The loans provide Wren Corporation with a business bad debt deduction.
D)None of the above.

Question 67

Shawn transfers property (basis of $40,000 and fair market value of $35,000)to Condor Corporation in exchange for § 1244 stock. The transfer qualifies as a nontaxable exchange under § 351; therefore,Shawn's basis in the Condor stock is $40,000. Five years later,Shawn sells the Condor stock for $25,000. With respect to the sale,Shawn has:

A)An ordinary loss of $15,000.
B)An ordinary loss of $10,000 and a capital loss of $5,000.
C)A capital loss of $15,000.
D)A capital loss of $10,000 and an ordinary loss of $5,000.
E)None of the above.

Question 68

George transfers cash of $150,000 to Grouse Corporation,a newly formed corporation,for 100% of the stock in Grouse worth $80,000 and debt in the amount of $70,000,payable in equal annual installments of $7,000 plus interest at the rate of 9% per annum.In the first year of operation,Grouse has net taxable income of $40,000.If Grouse pays George interest of $6,300 and $7,000 principal payment on the note:

A)George has dividend income of $13,300.
B)Grouse Corporation does not have a tax deduction with respect to the payment.
C)George has dividend income of $7,000.
D)Grouse Corporation has an interest expense deduction of $6,300.
E)None of the above.

Question 69

Earl and Mary form Crow Corporation.Earl transfers property,basis of $200,000 and value of $1,600,000,for 50 shares in Crow Corporation.Mary transfers property,basis of $80,000 and value of $1,480,000,and agrees to serve as manager of Crow for one year; in return Mary receives 50 shares of Crow.The value of Mary's services is $120,000.With respect to the transfers:

A)Mary will not recognize gain.
B)Earl will recognize a gain of $1,400,000.
C)Crow Corporation has a basis of $1,480,000 in the property it received from Mary.
D)Crow will have a business deduction of $120,000 for the value of the services Mary will render.
E)None of the above.

Question 70

Barry and Irv form Swift Corporation. Barry transfers cash of $100,000 and equipment (basis of $300,000 and fair market value of $400,000)for 50% of Swift's stock. Irv transfers land and building (basis of $510,000 and fair market value of $450,000)and agrees to manage the business for one year for the other 50% of Swift's stock. The value of Irv's services for one year is $50,000.
a.What is Barry's recognized gain? Basis in the Swift Corporation stock?
b.What are the tax consequences to Irv?
c.What are the tax consequences to Swift Corporation?

Question 71

Leonard transfers equipment (basis of $40,000 and fair market value of $100,000)for additional stock in Green Corporation. After the transfer,Leonard owns 90% of the stock. Leonard had claimed depreciation of $50,000 on the equipment prior to transferring it to Green Corporation. With respect to the transfer:

A)Leonard has ordinary income of $50,000.
B)Leonard has ordinary income of $50,000 and a § 1231 gain of $10,000.
C)Green Corporation has ordinary income of $50,000.
D)Green Corporation has a basis of $40,000 in the equipment and it will have no depreciation recapture if it later disposes of the equipment in a taxable transaction.
E)None of the above.

Question 72

Rita forms Finch Corporation by transferring land (basis of $125,000; fair market value of $750,000)which is subject to a mortgage of $375,000. Two weeks prior to incorporating Finch,Rita borrows $125,000 for personal purposes and gives the lender a second mortgage on the land. Finch Corporation issues stock worth $250,000 to Rita and assumes the two mortgages on the land. What are the tax consequences to Rita and to Finch Corporation?

Question 73

Perry organized Cardinal Corporation 10 years ago by contributing property worth $2 million,basis of $450,000,for 2,500 shares of stock in Cardinal,representing 100% of the stock in the corporation.Perry later gave each of his children,Brittany and Julie,750 shares of stock in Cardinal Corporation.In the current year,Perry transfers property worth $600,000,basis of $150,000,to Cardinal for 1,000 shares in the corporation.What gain,if any,will Perry recognize on the transfer?

Question 74

Joe and Kay form Gull Corporation.Joe transfers cash of $250,000 for 200 shares in Gull Corporation.Kay transfers property with a basis of $50,000 and fair market value of $240,000.She agrees to accept 200 shares in Gull Corporation for the property and for providing bookkeeping services to the corporation in its first year of operation.The value of Kay's services is $10,000.With respect to the transfer:

A)Gull Corporation has a basis of $240,000 in the property transferred by Kay.
B)Neither Joe nor Kay recognize gain on the exchanges.
C)Gull Corporation has a business deduction under § 162 of $10,000.
D)Gull capitalizes $10,000 as organizational costs.
E)None of the above.

Question 75

Penny,Miesha,and Sabrina transfer property to Owl Corporation for 75% of its stock.Nancy,their attorney,receives 25% of the stock in Owl for legal services rendered in incorporating the business.What are the tax consequences of these transactions? How should this be handled?

Question 76

Adam transfers cash of $300,000 and land worth $200,000 to Camel Corporation for 100% of the stock in Camel.In the first year of operation,Camel has net taxable income of $70,000.If Camel distributes $50,000 to Adam:

A)Adam has taxable income of $50,000.
B)Camel Corporation has a tax deduction of $50,000.
C)Adam has no taxable income from the distribution.
D)Camel Corporation reduces its basis in the land to $150,000.
E)None of the above.

Question 77

Nancy,Guy,and Rod form Goldfinch Corporation with the following consideration.

Goldfinch issues its 500 shares of stock as follows: 250 to Nancy,200 to Guy,and 50 to Rod.In addition,Guy gets $50,000 in cash.
a.Does Nancy, Guy, or Rod recognize gain (or income)?
b.What basis does Guy have in the Goldfinch stock?
c.What basis does Goldfinch Corporation have in the inventory? In the land and building?
d.What basis does Rod have in the Goldfinch stock?

Question 78

Nick exchanges property (basis of $100,000; fair market value of $3,000,000),for 75% of the stock of Yellow Corporation. The other 25% of the stock is owned by Gloria who acquired it several years ago. What are the tax consequences to Nick?

Question 79

In order to induce Yellow Corporation to build a new manufacturing facility in Knoxville,Tennessee,the city donates land (fair market value of $400,000)and cash of $100,000 to the corporation. Several months after the donation,Yellow Corporation spends $450,000 (which includes the $100,000 received from Knoxville)on the construction of a new plant located on the donated land.

A)Yellow recognizes income of $100,000 as to the donation.
B)Yellow has a zero basis in the land and a basis of $450,000 in the plant.
C)Yellow recognizes income of $500,000 as to the donation.
D)Yellow has a zero basis in the land and a basis of $350,000 in the plant.
E)None of the above.

Question 80

George (an 80% shareholder)has made loans to Mountainview Corporation that become worthless in the current year. George is not employed by Mountainview.

A)George is not permitted a deduction for the worthless loans.
B)The loans provide a nonbusiness bad debt deduction to George in the current year.
C)The loans provide George with a business bad debt deduction.
D)George may claim an ordinary loss as to the worthless loans.
E)None of the above.