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Buck Henry intends to form PAR Corporation by transferring unimproved land held for investment for several years with a basis of $20,000, a fair market value of $90,000, and subject to a recourse debt in the amount of $30,000 that was incurred several years ago for a valid business purpose. In return, Buck will receive all of PAR's stock with a fair market value of $60,000 and PAR will assume the recourse debt. Buck wants to know whether he will have to recognize any gain as a result of his proposed formation of PAR Corporation. If so, he wants you to recommend alternatives that would avoid gain recognition on the incorporation. For the current year PAR Corporation had book net income of $150,000 before income taxes.Included in the determination of this amount were the following gain and losses from sale of property held for more than one year.
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