Chapter 10 - Property: Dispositions
[LO 1] Compare and contrast different ways in which a taxpayer triggers a realization
event by disposing of an asset.
A realization event for tax purposes is created in many ways.
disposal will result in a sale or other disposition.
These include a sale, trade,
gift to charity, disposal to the landfill, or destruction in a natural disaster.
sale or trade (exchange), the taxpayer receives something of value in return for
In contrast, a charitable contribution, disposal, or destruction from a
natural disaster generally results in a loss of any remaining basis in the asset
without compensation (unless reimbursed by insurance).
[LO 1] Potomac Corporation wants to sell a warehouse that it has used in its business
for 10 years.
Potomac is asking $450,000 for the property.
The warehouse is subject
to a mortgage of $125,000.
If Potomac accepts Wyden Inc.’s offer to give Potomac
$325,000 in cash and assume full responsibility for the mortgage on the property,
what amount does Potomac realize on the sale?
When the property disposed of is subject to a liability and the buyer assumes
the liability, the relief of debt increases the amount realized.
amount realized consists of $450,000, which is cash of $325,000 plus $125,000
relief of debt.
This assumes that the buyer hypothetically transfers cash to the
seller in order to pay off the mortgage.
[LO 1] Montana Max sells a 2,500-acre ranch for $1,000,000 in cash, a note
receivable of $1,000,000, and debt relief of $2,400,000.
He also pays selling
commissions of $60,000.
In addition, Max agrees to build a new barn on the property
(cost $250,000) and spend $100,000 upgrading the fence on the property before the
What is Max’s amount realized on the sale?
Anything received by the seller during a sale or exchange is included in the
Most dispositions result in cash to the seller.
amount realized includes, but is not limited to, cash, the fair market value of
any other property received (e.g. marketable securities or a similar asset), or
relief of debt.
In addition, selling expenses reduce the amount realized.
Therefore, Max’s amount realized includes the $1,000,000 of cash, $1,000,000
note receivable, relief of debt of $2,400,000, and is reduced by selling
commissions of $60,000 (selling expenses reduce the amount realized, S.C.
Chapin, CA-8, 50-1 USTC ¶9171). Anything the seller gives up in the
transaction is added to