This year, Randy paid $29,650 of interest on his residence. (Randy borrowed $472,000 to buy his residence, and it is currently w
orth $522,000.) Randy also paid $3,050 of interest on his car loan and $5,025 of margin interest to his stockbroker (investment interest expense). How much of this interest expense can Randy deduct as an itemized deduction under the following circumstances? a. Randy received $2,200 of interest this year and no other investment income or expenses. His AGI is $75,000.
b. Randy had no investment income this year, and his AGI is $75,000.
It appears that Ted wants to gain control per the requirements of section 351. However, Ted was short. Ted only has 79% of the stock ownership and not 80% or more. There for he does not have control. Since he does not have control, he is unable to qualify for the nontaxable transaction under section 351.
The Regulations provide that stock issued for property whose value is (equal/ relatively small/ relatively large) compared to the (fair market value of the assets/ value of the stock already owned) will not be treated as issued in return for property.
