Does the above transaction qualify as a sec 351 exchange


An Introduction to the Tax Treatment of Various Business Entities

Incorporation of Plummet Company

Plummet Company is created with the following asset contributions. John and Jill are equal owners in this new business venture.

Shareholder Assets Basis Fair Market Value

John Cash Services

$100,000

50,000

$100,000

50,000

Jill Land 40,000 200,000*

The land is subject to a liability in the amount of $50,000 that the Company assumes.

Questions:

Does the above transaction qualify as a Sec. 351 exchange? Show your computations.

Compute shareholder basis in the shares received in the exchange.

Prepare a tax balance sheet for Plummet Company.

Are there any benefits to the owners and company if this transaction is considered to fall under Sec. 351?

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Corporate Finance: Does the above transaction qualify as a sec 351 exchange
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