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1. A, B, and C decided to organize the ABC Corporation with the following investments: A pays cash of $50,000 for 50 shares B contributes land worth $40,000 (basis to B of $10,000) for 40 shares C.- performs services on behalf of ABC Corporation (worth $10,000) for 10 shares. Assume each share of stock has a value of $1,000 A. How much gain will A, B,and C recognize? Sec. 351(a), Regs. Sec. 1.341-1 (a), Rev. Rul. 69-357, 1969-1 C.B. 101, and Sec. 351 (e)(4). what basis will A, B and C have in the stock they receive? Sec. 358(a)(1). B. what basis will ABC Corporation have in the land received from B? Sec. 362(a). C.
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Answers are highllighted in yellow: Solution: A) Gain Recognization: Answer: 0 $30,000 0 Explanation Because, no gain is recognized on cash contribution Gain will be recognized as section 351 doesn apply (with 80% holding after contribution) Only ordinary income will be recognized. Hence, $0 gain. B) Basis Answer: $50,000 $ 40,000 $ 10,000 As $50K cash contributed As $10000 basis + Gain $30000 recognized Because, $10000 will be taxed as ordinary income Answer: ABC Basis in Land40,000Shareholders Carryover basis is considered as basis of Corp

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