Fact Pattern. On January 1 of Year one Ant and Bee formed X Corporation. On that date Ant contributed land with a FMV of $10,000 and an adjusted…

Fact Pattern.

On January 1 of Year one Ant and Bee formed X Corporation. On that date Ant contributed land with a FMV of $10,000 and an adjusted basis to A of $3,500. B contributed two capital assets: CA #1 (FMV $6,000, AB $8,000), and CA#2, FMV $6,000, AB $5,000), B also contributed a liability (which had a legitimate business purpose) of $1,000 which was assumed by X. A received 100 shares in exchange and B received 100 shares and $1,000 cash in the exchange.

DURING YEAR 1

  • X received $5,000 revenue from operations
  • On July 1 X distributed $1,000 cash to A and $1,000 cash to B.
  • On October 15 X received $2,000 of dividends from Y corp. (X owns < 1% of Y stock)
  • On December 21 X sold CA #1 for $5,000

DURING YEAR 2

  • On January 1, In an unrelated transaction, X received a capital asset from W (“CAW”) with a FMV of $15,000 and an adjusted basis of $12,000 to and issues 100 shares of X stock which it gave to W.
  • Also on January 1 X purchased a Section 179 asset for $1,000
  • On April 1 X sold CAW for $16,000  capital gain:1,000
  • On July 1 X distributed $5,000 cash to each of A, B and C ($15,000 total).
  • X received $4,000 revenue from operations    
  • X paid $1,000 in federal tax.

DURING YEAR 3

  • X receives $1,000 revenue from operations
  • X distributed $333.33 to each of A, B and W
  1. What is X’ taxable income in Years 1, 2 and 3?
  1. What income, gain or loss does A recognize in Year 1?
  1. What income, gain or loss does B recognize in Year 2?
  1. What is X’ Accumulated E&P at the beginning of Year 3?
  1. What income, gain or loss does W recognize in Year 2?
  1. What income, gain or loss does W recognize in Year 3?

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