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Gravity Corporation Creates Earth Corporation

Question 52

Multiple Choice

Gravity Corporation creates Earth Corporation.It transfers most of its assets (net value $900,000) to Earth.At approximately the same time,Magnet Corporation also transfers all of its assets (net value $90,000) to Earth.Gravity liquidates by transferring its remaining assets,$100,000 cash and 1,000 shares of Earth,to its sole shareholder,Zia,in exchange for all of her Gravity stock.Zia's basis in her Gravity stock was $300,000.Magnet liquidates by transferring 100 shares of Earth to its sole shareholder,Amos,in exchange for all of his Magnet stock.Amos's basis in his Magnet stock was $150,000.How will this transaction be treated for tax purposes?


A) This is a taxable transaction. Zia recognizes $700,000 gain and Amos recognizes $60,000 loss.
B) This qualifies as a "Type D" reorganization. Neither Zia nor Amos recognizes a gain or loss.
C) This qualifies as a "Type C" reorganization. Zia recognizes $100,000 gain, Gravity also recognizes $100,000 gain, but Amos will not recognize his loss.
D) This qualifies as a "Type A" reorganization. Zia recognizes $100,000 gain, but Amos will not recognize any loss.
E) None of the above.

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