1. A contributes property to X, a newly formed corporation, in exchange for 75 shares. As part of the same transaction, B contributes services to X in exchange for the remaining 25 shares. Does § 351 apply to the contributions of A and B? Why or why not?
2. A contributes to X, a newly formed corporation, property worth $80 with a basis of $60 in exchange for 20 shares. Assume the stock is worth $1 per share. As part of the same transaction, B contributes to X property worth $20 with a basis of $10 in exchange for 80 shares. How much income must A and B recognize and why (assume that if § 351 applies, A's basis in the stock A receives is the same as A's basis in the property A contributes)?
3. In each of the following scenarios, determine in regards to the exchange with X:
a) A's amount realized
b) A's gain or loss realized
c) A's gain or loss recognized and the character thereof
d) A's basis in the X stock received
e) A's holding period for the X stock received (tacked or not?)
f) X's basis in the property received
g) X's holding period for the property received (tacked or not?)
h) The amount and character of X's gain if X immediately sells the property for $100
And the following in regards to the subsequent sale from A to B:
i) A's gain or loss realized
j) A's gain or loss recognized and the character thereof
k) A's basis in the remaining shares
l) B's basis in the purchased shares from A
Assumptions: Except as otherwise stated, A starts out with non-depreciable real property (a capital asset) worth $100 (adjusted basis $40) and ends up with cash of $50 plus a 50% interest (worth $50) in X, a newly organized corporation that owns the property.
(a) A transfers the property to X in exchange for all of X's stock. Shortly thereafter, A sells half of his X stock to B for $50. The stock sale is a "separate" event from the prior incorporation transaction.
(b) Same as (a), except the stock sale is an integral part of the incorporation plan.