Question

Exercise 20-14 (LO. 1) Osprey Corporation stock is owned by Pedro and Pittro, who are unrelated. Pedro and Pittro each own 50% and Pittro owns 50% of the stock in the corporation. Osprey has the following assets (none of which were acquired in a § 351 or contribution to capital transaction) that are distributed in complete liquidation of the corporation Adjusted Fair Market Value Cash Land Equipment Basis $300,000 200,000 250,000 $300,000 440,000 140,000 Assume that Osprey Corporation distributes the land to Pedro and the cash and equipment to Pittro a. Determine Osprey's recognized gain or loss on the distribution of land Osprey recognizes a gain of $ on the distribution of the land b. Determine Osprey's recognized gain or loss on the distribution of the equipment. The lossof $ on the equipment is allowed . Feedback Check My Work when property is transferred to a corporation in a § 351 transaction or as a contribution to capital, carryover basis rules generally apply. Without special limitations, a transfer of loss property in a carryover basis transaction would present opportunities for the duplication of losses

Answer 1

U.S. Code § 336. RECOGNITION OF GAIN OR LOSS ON PROPERTY DISTRIBUTED ON COMPLETE LIQUIDATION

(a)General rule

Except as otherwise provided in this section or section 337, gain or loss on distribution of property under liquidation shall be recognized to a liquidating corporation ,as if such property were sold at its fair market value to the distributee.

(b)Treatment of liabilities

If any property is subjected to a liability or the shareholder assumes a liability of the liquidating corporation during liquidation in connection with the distribution, the as per subsection (a) of section 337, the fair market value of such property shall be treated not less than the amount of such liability.

So, therefore, Osprey recognised a gain of (440000-200000)= $ 240000 on the distribution of land.

Osprey recognised a loss of (140000-250000)= $ 110000 on the distribution of the equipment.