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w 5. Section 351 Multiple Assets Transfer - Exercise Xercise Zhang transfers three assets to newly formed West Corporation in

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As per Section 351 any loss will not be realized but if any boot is received along with the qualified stock then the stock and boot will be allocated on pro-rata basis on the basis of the different types of property transferred. Loss on one asset will not be allowed to set off from the gain of another.

Basis FMV

Share and boot

(pro-rata)

Gain/(loss)
Asset 1 40,000 30,000 39,024 9,024
Asset 2 15,000 40,000 14,634 (25,366)
Asset 3 27,000 10,000 26,341 16,341

Total stock and boot: 80,000 (20,000+60,000)

Total of basis: 82,000

Divide on pro rata basis:

Asset 1: 80,000*40,000/82,000= 39,024

Asset 2: 80,000*15,000/82000= 14,634

Asset 3: 80,000*27,000/82,000= 26,341

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