Question

The stock of Quail Corporation is held as follows: 85% by Pheasant Corporation and 15% by Gisela, an individual. Quail Corporation is liquidated in December of the current year pursuant to a plan adopted earlier in the year. At the time of its liquidation, Quail Corporation has assets with a basis of $730,000 and fair market value of $1 million. Quail Corporation distributes the property pro rata to Pheasant Corporation and to Gisela.

a. Compute Quail’s recognized gain or loss on the distribution of property to Pheasant.
b. Compute Quail’s recognized gain or loss on the distribution of property to Gisela.

Answer 1

solution:

Requirement A:

Quail’s recognized gain or loss on the distribution of property to Pheasant Corporation is ZERO.

Explanation:

1) Liquidation of Quail Corporation is a parent-subsidiary liquidation between Quail Corporation and Pheasant Corporation. So, no need to recognize gain or loss on liquidation distribution.

Requirement B:

Quail’s recognized gain or loss on the distribution of property to Gisela is $ 40,500.

Explanation:

1) Gisela is a minority shareholder in Quail Corporation.

2) So, quail`s corporation should recognize gain up to their shareholding of [$1,000,000 - $ 730,000] * 15% = $40,500