Question

The stock of Cooper Corporation is​ 70% owned by Carole and​ 30% owned by​ Carole's brother, Chris. During​ 2017, Chris transferred property​ (basis of​ $100,000 and FMV of​ $120,000) as a contribution to the capital of Cooper. During February​ 2018, Cooper adopted a plan of liquidation and subsequently made a pro rata distribution of the property back to Carole and Chris. At the time of the​ liquidation, the property had an FMV of​ $80,000. What amount of loss can be recognized by Cooper on the distribution of​ property?

Answer 1

Answer:

$0

Explanation:

Since 100% of Cooper Corporation's stock were owned by Carole and Chris (who are siblings), then no one can recognize any loss or gain from the contribution of property (nor the distribution of property). Under section 351, no gain or loss can be recognized for the contribution of property in exchange for stocks in a controlled corporation.

Since the contribution was made through a carryover basis transaction less than 5 years before the liquidation, the distribution is carried out in the same way.