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Subject Topic: Becker Simulation Question (Topic Closed Topic Closed) Post ReplyPost New Topic
  
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akh89
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Posted: 10 Feb 2012 at 13:12 | IP Logged  

Hey everyone,

I had to sign up for CPAnet just because of this one question, I just am failing to see where the answer is coming from.  The information that pertains to my question is as follows:

Mitchell contributes property and cash to form a corporation.
FMV of property contributed: $80,000
Liability associated with the property: $50,000
Mitchell's basis in property: $40,000
Cash contributed: $20,000

So I get that his realized gain is $40,000 ($80,000-$40,000) and his recognized gain is $10,000 (liability assumed by corp. exceeds basis by $10,000).  What I don't get is the corporation's basis for the property received.  I have calculated that the corporation's basis in the property would be $50,000.  I am basing this off of R3 in Becker where it says the general rule is the corporation's basis is the greater of:

a) Adjusted basis of transeror (plus any gain recognized by transferor)
or
b) Debt assumed by the corporation.

Well for a) I get $50,000 ($40,000+$10,000) and for b) I get $50,000.  That gets me to my answer of $50,000.  The Becker simulation says the basis for the corporation is $40,000 since that was Mitchell's basis.  What?

Any help would be greatly appreciated.
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CPA#1
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Posted: 10 Feb 2012 at 14:12 | IP Logged  

He also contributed cash of $20,000. The liability does not exceed the $60,000 (40k for property and 20k for cash). Thus, no gain is recognized. So, the basis of Mitchell's property is the basis that the Corporation will use.


__________________
FAR: 52,66,73,61,89
AUD: 47,87
BEC: 80
REG: 64,74,84

DONE!!!!!!!
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akh89
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Joined: 10 Feb 2012
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Posted: 10 Feb 2012 at 14:30 | IP Logged  

Ah, that makes sense.  I always thought that you would account for the cash and the property separately when assigning basis to the corporation.  So, if I understand correctly, he would not recognize a gain at all?  In order to recognize a gain, the liability would have to be greater than $60,000 ($40,000 NBV + $20,000 cash), correct?  And if that were the case, I'm assuming the corporation's basis would be the value of that liability over $60,000.

I had never seen a problem like that before.  I stared at it and my book for about 30 minutes trying to figure it out.  Thank you so much for your help.
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CPA#1
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Posted: 10 Feb 2012 at 14:57 | IP Logged  

Yes, the corporation would have a basis of $40,000 for the property and $20,000 for the cash.

The liabilities assumed must exceed then TOTAL basis of the property contributed in order for a gain to recognize. Property is considered to be anything other than services. So, cash is included as "property."


__________________
FAR: 52,66,73,61,89
AUD: 47,87
BEC: 80
REG: 64,74,84

DONE!!!!!!!
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