Exam 9: Tax-Deferred Exchanges

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What is the difference between a carryover basis and a substituted basis?

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If a taxpayer's personal residence is involuntarily converted, the taxpayer can only defer gain by acquiring a new residence in the required time period using IRC §1033.

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How long does a taxpayer who realizes gain have to replace real property that has been condemned?

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Elizabeth exchanges an office building valued at $400,000 with a $75,000 mortgage and adjusted basis of $180,000 for land valued at $275,000. What is Elizabeth's basis in the land received in the exchange?

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Four shareholders form a new corporation in exchange for stock with a fair market value of $1,000 per share. Benjamin transfers investment land (current fair market value of $35,000) that he purchased 10 year ago for $15,000. In exchange, Benjamin receives 30 shares of stock and $5,000 cash. Andrew transfers a machine with a basis of $45,000 and a fair market value of $35,000. Andrew receives 30 shares of stock and $5,000 cash. Emily transfers a rental office building (current fair market value of $45,000) that she purchased 20 years ago for $60,000. Its current basis is $15,000 after recognition of $45,000 in depreciation expense. The corporation assumes the $20,000 balance on the original mortgage and Emily receives 25 shares of stock from the corporation in the exchange. Jackson provided the legal services to organize the corporation (value $5,000) and contributes $10,000 in cash in exchange for 15 shares of stock. How much income or gain does Jackson recognize?

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In a qualified reorganization:

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How is the basis of stock received for appreciated property in a Section 351 transfer determined?

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Sophie received a 30 percent interest in a general partnership in exchange for property valued at $35,000 (adjusted basis = $25,000) and services valued at $5,000. In addition, the partnership assumed the $10,000 liability on the property. What is Sophie's basis in her partnership interest?

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How is a new partner's basis in a partnership interest determined if the partnership has no liabilities?

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What effect do liabilities assumed by the partnership have on a partner's basis?

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Which type of reorganization does not entail a transfer of assets for stock?

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Corporation P acquires 95 percent of Corporation T's assets for $19.5 million of P's stock in a qualifying reorganization. The assets transferred have a basis of $14 million. T retained $500,000 of cash to pay its remaining liabilities. It only used $200,000 of the cash and the remaining cash and P stock are distributed to T's shareholder, who has a basis of $14 million in her stock. What is the gain recognized on this reorganization?

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Wally's investment real estate was condemned on November 14, 2018. On February 14, 2019, he received $250,000 for the property that had a basis of $210,000. What is the last date that Wally can acquire replacement property to avoid gain recognition?

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To defer gain recognition on an involuntary conversion, qualifying property must be obtained within a specified time period.

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On November 4, 2017, Tom purchased 2,000 shares of DDD stock for $20,000. On June 2, 2018, Tom sold the 2,000 shares for $14,000. On June 30, 2018, he purchased 1,000 shares of DDD stock for $5,000. What is Tom's realized and recognized gain or loss on the June 2, 2018 sale and his basis in the stock from the June 30 purchase?

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The taxpayer-use test for qualifying replacement property

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Elizabeth exchanges an office building valued at $400,000 with a $75,000 mortgage and adjusted basis of $180,000 for land valued at $275,000. What is Elizabeth's realized gain on the exchange?

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Twining Corporation has some land it wants to trade for a building owned by Clopp Corporation. Clopp does not want to exchange the building because it wants to recognize its loss on the building. Twining, however, does not want to recognize its gain. What alternative(s) does Twining have that will allow it to avoid recognizing gain?

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Kaitlin purchased 100 shares of Norton Corporation stock for $11,500 on January 1, 2015. March 1, 2018, she purchased 30 additional shares of Norton Corporation for $3,000. On March 20, 2018, she sold 25 shares of the 100 shares she had purchased in 2015, for $2,500. What is Kaitlin's recognized gain or loss on the sale of the stock?

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A theft loss of $10,000 cash by an individual results in a $10,000 casualty loss deduction.

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