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Jack and John exchange inventory and machinery with a combined basis of $100,000

ID: 2431536 • Letter: J

Question

Jack and John exchange inventory and machinery with a combined basis of $100,000 and a fair market value of $500,000 to ABC corporation in return for 100% of its stock. Prior to a §351 transaction, Jack and Jill agreed that Jack would sell Jill his 50% interest in ABC corporation within one week of obtaining the shares. How much gain or loss is recognized by Jack and John combined on the §351 exchange?

A. $500,000

B. $200,000

C. $400,000

D. $0, since this transfer is subject to the non-recognition rule of §351

Explanation / Answer

They will have combined basis of $ 100,000 each having share of $ 50000. Sale of share by Jack would be for $ 250,000 and attract gain of $ 250000 - $ 50000 = $ 200000 combined of Jack and John.