Part 1:
On June 3 of current year Eric Florence and George form Wildcat Corporation and transfer the following items:
Transferor Asset Basis to Transferor FMV # of Com Share
Eric Land $200000 $50000 500
Florence Equipment -0- 25000 250
George Legal Services -0- 25000 250
Eric purchased the land (a capital asset) 5 years ago for &200000. Florence purchased the equipment three years ago for $48000. The equipment has been
fully depreciated.
a. Does the transaction meet the requirement of Sec. 351?
b. What are the amount and character of the gains and losses recognized by Eric Florence George and Wildcat?
c. What is each shareholder%u2019s basis in his or her Wildcat stock? When does the holding period for the stock begin?
d. What is Wildcat%u2019s basis in the land equipment and services? When does the holding period for each property begin?
Part 2:
Assume the same facts above:
a. Under what circumstances is the tax result beneficial and for which shareholders?
b. Can you suggest ways to enhance the tax benefit?