Prob. 1: True-False
A and B establish X corporation. A transfers land with a FMV of $70,000, and a
basis of $50,000 for 70 shares of X. B provides services worth $30,000 for 30
shares of X. A and B are in control of X for pur
Prob. 1 (Control Requirement under Sec. 351)
The following are independent situations. Unless otherwise indicated, assume the individuals
involved are unrelated.
Oliver transfers property to Samson Corporation in exchange for 75% of Samsons
Prob. 1 (Transfer of Property and Services to a Controlled Corporation; Loss Limitation
A, B, and C, who are unrelated individuals, form March Corporation to operate a book
store. A, B, and C transfer property and perform services as follows:
The George Washington University
School of Business
Department of Accountancy
Course Number: Accy 6403-10
Course Title: Corporate Tax
Time & Location: Thursday 7:10-9:40 p.m., FNGR 210
Course Description: A study of Federal income taxation of
US CORPORATE INCOME TAX
Corporate tax rates: statutory vs.
US top rate of 35% not mean
corporations pay 35% of F/S net income
F/S net income taxable income
Factors accounting for differences:
1. Accelerated depreci
NOTES FOR 1.29.15
Revisit contingent liabilities transaction, Black & Decker v. U.S., U.S. Dist.
Md. (Aug. 2004).
1. Taxpayer had recognized substantial capital gains in 1998; taxpayer needs
a capital loss tax shelter to offset these gains.
Taxpayer is l
357(a): general rule
Personal liabilities not ignored
Liabilities in excess of basis are taken into account
357(c)(3): exception to exception
Liabilities ignored if deductible
NOTES FOR 1.29.15
Clarify boot within gain rule, i.e., the lesser of, etc.
Constructing a tax shelter: four steps
1. Bongiovanna v. Comr., 470 F. 2d 921 (2d Cir. 1972), revg T.C. Memo 1971262.
Tax Court upheld Comr.s determination that 357(c) applied to t