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I have to do a tax research memo on this question and I am completely lost. Can you guide or point me in the right direction?
I have to do a tax research memo on this question and I am completely lost. Can you guide or point me in the right direction? I also need to support my answer with relevant court cases.
John plans to transfer the assets and liabilities of his business to Newco in exchange for
all of Newco's stock. The assets have a $250,000 basis and an $800,000 FMV. John also
plans to transfer $475,000 of business related liabilities to Newco. Under Sec. 357(c), can
John avoid recognizing a $225,000 gain (the excess of liabilities over the basis of assets
transferred) by transferring a $225,000 personal promissory note along with the assets
and liabilities?
