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Basis Adjustment Solution

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Submitted By stbfitess22
Words 344
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Topic: Basis adjustment for loss property
Harry transferred the following assets to the Lowell Corporation in exchange for all of its stock in a transaction that qualified for Sec. 351 treatment:
Adjusted
basis
Fair
value
Accounts receivable - 0 - 35,000
Equipment 90,000 60,000
Land 100,000 125,000
Building 90,000 30,000
280,000 250,000
Required:
[1] Compute Harry’s stock basis.
[2] Compute Lowell’s tax basis in the assets transferred by Harry.
[3] Compute Harry stock basis, if both he and the corporation elect to make the basis adjustment to his stock basis.

Solution: Basis adjustment for loss property
Harry transferred the following assets to the Lowell Corporation in exchange for all of its stock in a transaction that qualified for Sec. 351 treatment:
Adjusted
basis
Fair
value
Accounts receivable - 0 - 35,000
Equipment 90,000 60,000
Land 100,000 125,000
Building 90,000 30,000
280,000 250,000
Required:
[1] Compute Harry’s stock basis.
[2] Compute Lowell’s tax basis in the assets transferred by Harry.
[3] Compute Harry stock basis, if both he and the corporation elect to make the basis adjustment to his stock basis.
Solution:
[1] and [2] Harry’s stock basis is $280,000; while Lowell’s tax basis in the assets is $250,000 because of the net built-in loss rules. The net built-in loss is allocated between the equipment and the building as follows:
Adjusted
basis
Fair
value
Net built-in gain (loss)
Proportion of loss Tax basis Accounts receivable - 0 - 35,000 +35,000 - 0 -
Equipment 90,000 60,000 (30,000) 30/90 x (30,000) 80,000
Land 100,000 125,000 +25,000 100,000
Building 90,000 30,000 (60,000) 60/90 x (30,000) 70,000
280,000 250,000 (30,000) 250,000
[3] Harry’s stock basis is $250,000 (280,000 – 30,000 built-in loss); while Lowell’s tax basis in the assets is $280,000.
Adjusted
basis
Accounts receivable - 0

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