Question

Carl transfers land to Cardinal Corporation for 90% of the stock in Cardinal Corporation worth $20,000 plus a note payable to Carl in the amount of $40,000 and the assumption by Cardinal Corporation of a mortgage on the land in the amount of $100,000. The land, which has a basis to Carl of $70,000, is worth $160,000.
a. Cardinal Corporation will have a basis of $160,000 in the land transferred by Carl.
b. Carl will have a recognized gain on the transfer of $30,000
c. Carl will have a recognized gain on the transfer of $90,000.
d. Cardinal Corporation will have a basis of $70,000 in the land transferred by Carl.
e. None of these choices are correct.

Answer 1

Answer:

e. None of these choices are correct.

Explanation:

Carl's gain = value of the note received + value of the mortgage - land's basis = $40,000 + $100,000 - $70,000 = $70,000

Snice the mortgage is higher than the basis ($100,000 higher than $70,000), this must be recognized as a Section 357 gain. The note receivable must also be recognized as gain since it doesn't qualify for Section 351.