On May 1 of the Current Year, Kiara, Victor, Pam

question 101

Essay

On May 1 of the current year, Kiara, Victor, Pam, and Joe form Newco Corporation with the following investme
Property Transferred $\begin{array}{lllll}&&&\text { Number of }&\text { common }\\\text { Transferor } & \text { Asset } & \text { Basis to Transferor } &\text { FMV }&\text { shares issued }\\\hline\text { Kiara }&\text { Land } & \$ 12,000 & \$ 30,000 \\&\text { Building } & 38,000 & 70,000&400 \\&\text { Mortgage and the } & & \\&\text { land \& building } & 60,000 & 60,000 \\\text { Victor }&\text { Equipment } & 25,000 & 40,000 &300\\\text { Pam } &\text { Van } & 15,000 & 10,000&50 \\\text { Joe }&\text { Accounting Services } & 0 & 10,000&100\end{array}$ Kiara purchased the land and building several years ago for $12,000 and $50,000, respectively. Kiara has claimed straight- line depreciation on the building. Victor also received a Newco Corporation note for $10,000 due in thre The note bears interest at a rate acceptable to the IRS. Victor purchased the equipment three years ago for $50,00 also receives $5,000 cash. Pam purchased the van two years ago for $20,000.
a) Does the transaction satisfy the requirements of Sec. 351?
b) What are the amounts and character of the reorganized gains or losses to Kiara, Victor, Pam, Joe, and Newco Corporation?
c) What is each shareholder's basis for his or her Newco stock? When does the holding period for the stock beg
d) What is Newco Corporation's basis for its property and services? When does its holding period begin for eac property?

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Definitions:

Convergent Thinking

A problem-solving technique that involves focusing on a finite number of solutions rather than proposing multiple possibilities.

Creative Intelligence

A facet of intelligence related to the ability to deal with new situations using creative and innovative solutions and imaginative problem-solving.

Divergent Thinking

A cognitive process that involves generating creative ideas by exploring many possible solutions.

Hereditary Studies

Research into how characteristics and conditions are transmitted from parents to offspring through genes.