This year, Blake, Charlotte, and Olivia form Heron Corporation. Blake contributes land purchased as an investment four years ago for $25,000 that has a $30,000 FMV in exchange for 30 shares of Heron stock. Charlotte contributes machinery (Sec. 1251 property) purchased four years ago and used in her business having a $50,000 adjusted basis and a $30,000 FMV in exchange for 30 shares of Heron stock. Olivia contributes services worth $15,000 and $5,000 cash in exchange for 20 shares of Heron stock.
a) What is the amount of Blake’s recognized gain or loss?
b) What is Blake’s basis in his Heron shares? When does his holding period begin?
c) What is the amount of Charlotte’s recognized gain or loss?
d) What is Charlotte’s basis in her Heron shares? When does her holding period begin?
e) How much income, if any, must Olivia recognize?
f) What is Olivia’s basis in her Heron shares? When does her holding period begin?
g) What is Heron Corporation’s basis in the land and the machinery? When does its holding period begin? How does Heron Corporation treat the amount paid to Olivia for services?
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