ACCT 541 Tax
Superior Trading, LLC, Jetstream Business Limited, Tax Matters Partner, et al., v. Commissioner
137 T.C. No. 6 (2011)
On May 7, 2003 Warwick Trading, LLC (Warwick) entered into a contribution agreement with
Lojas Arapua, S.A.
Whether Trudy Thompson (Mrs. Thompson) realizes gain or loss on the complete
liquidation of ABC Incorporated (ABC) and, if so, whether such a gain or loss is
recognized and Mrs. Thompsons basis and holding period of what Mrs. Thompson
Whether Sally Client (Client) realizes gain or loss on the incorporation of the auto
repair shop (Repair Shop) and, if so, whether such a gain or loss is recognized and
Clients basis and holding period of what Client receives upon incorporation.