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Corporate Tax Special Situations

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Submitted By kmotsinger
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Corporation Special Situations and Organization Structure (50 pts)

Jane, Hunter, Renee, and Lynn form Bradley Corporation with the following consideration: | Basis to Transferor | Fair Market Value | Number of Shares Issued | From Jane - Equipment ($20,000 of depreciation taken by Jane in prior years) | $90,000 | $270,000 | 50* | From Hunter - Secret process | $5,000 | $100,000 | 20 | From Renee - Cash | $50,000 | $50,000 | 10 | From Lynn - Inventory | $85,000 | $130,000 | 20** |

*Jane receives $20,000 cash in addition to the 50 shares
**Lynn receives $30,000 cash in addition to the 20 shares.

Assume the value of each share of Bradley Corporation stock is $5,000. As to these transactions, provide the following information in an MSWord document or Excel spreadsheet: 1. Jane’s recognized gain or loss and its treatment. 2. Jane’s basis in the Bradley stock. 3. Bradley Corporation’s basis in the equipment. 4. Hunter’s recognized gain or loss. 5. Hunter’s basis in the Bradley stock. 6. Hunter’s Corporation’s basis in the secret process. 7. Renee’s recognized gain or loss. 8. Renee’s basis in the Bradley stock. 9. Lynn’s recognized gain or loss. Identify the treatment given to any such gain or loss. 10. Lynn’s basis in Bradley’s stock. 11. Bradley Corporation’s basis in the inventory.
For each item, numbered from 1-11 to sync with the assignment, provide a brief (1-3 sentences) explanation of how you calculated your solution.

Answers: | A | B | C | D | E | F | | Basis of Equipment transferred | FMV of Stock Rec’d | Boot Rec’d | Real. gain (B+C-A) | Recog. Gain(lesser of C or D) | Basis of Stock in Bradley(A-C+E) | From Jane: Equipment | 90,000 | 270,000 | 20,000 | 200,000 | 20,000 | 90,000 | From Hunter: Secret process | $5,000 | 100,000 | 0 | 95,000 | 0 | 5,000 | From Renee-Cash | $50,000

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