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The stock in Rhea Corporation is owned by Jennifer (80%) and Lucy (20%) , mother and daughter. In a liquidation of the corporation in the current year, Rhea distributes land that it purchased two years ago for $675,000 to Lucy. The property has a fair market value on the date of distribution of $450,000. One year later, Lucy sells the land for $400,000. What loss, if any, will Rhea Corporation recognize with respect to the distribution of land?


A) $0
B) $45,000
C) $225,000
D) $275,000
E) None of the above

F) C) and D)
G) A) and C)

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The tax treatment of reorganizations almost parallels the Federal income tax treatment for like-kind exchanges.

A) True
B) False

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Pursuant to a complete liquidation, Lilac Corporation distributes the following assets to its unrelated shareholders: land held for three years as an investment (basis of $300,000, fair market value of $600,000) , inventory (basis of $100,000, fair market value of $80,000) , and marketable securities held for four years as an investment (basis of $200,000, fair market value of $240,000) . What are the tax consequences to Lilac Corporation as a result of the liquidation?


A) Lilac Corporation would recognize no gain or loss on the liquidation.
B) Lilac Corporation would recognize a net capital gain of $320,000.
C) Lilac Corporation would recognize a net capital gain of $340,000 and an ordinary loss of $20,000.
D) Lilac Corporation would recognize a net capital gain of $340,000.
E) None of the above.

F) C) and D)
G) B) and E)

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Which of the following statements is true?


A) The dollar amounts involved in reorganizations are generally substantial? thus, it is important that the financial and tax treatment of the reorganization is consistent.
B) A letter ruling indicates the income tax treatment the IRS will apply to the proposed corporate restructuring transaction.
C) Careful planning can ensure that all gains recognized by individual shareholders receive beneficial dividend treatment.
D) None of the statements is true.

E) B) and C)
F) A) and D)

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Section 332 can apply to a parent-subsidiary liquidation even if the subsidiary corporation is insolvent on the date of the liquidation.

A) True
B) False

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Explain whether shareholders are exempted from gain/loss recognition in nontaxable corporate reorganization or the gain/loss recognition is merely postponed. If postponed, what is the vehicle for ensuring the postponed gain/loss will be recognized in the future?

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In reorganizations, neither gain nor los...

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The Federal income tax treatment of a corporate restructuring is an extension of allowing entities to form without taxation.

A) True
B) False

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During the current year, Ecru Corporation is liquidated and distributes its only asset, land, to Kena, the sole shareholder. On the date of distribution, the land has a basis of $250,000, a fair market value of $650,000, and is subject to a liability of $500,000. Kena, who takes the land subject to the liability, has a basis of $120,000 in the Ecru stock. With respect to the distribution of the land, which of the following statements is correct?


A) Kena recognizes a gain of $530,000.
B) Ecru Corporation recognizes a gain of $250,000.
C) Kena recognizes a gain of $30,000.
D) Kena has a basis of $250,000 in the land.
E) None of the above.

F) B) and E)
G) A) and E)

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The basis for the acquiring corporation in the target's assets is increased by any gain recognized by the target.

A) True
B) False

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Liquidation expenses incurred by a corporation are generally deductible as ยง 162 trade or business expenses.

A) True
B) False

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All of the following statements are true about corporate reorganization except:


A) Taxable amounts for shareholders are classified as a dividend or capital gain.
B) Reorganizations receive treatment similar to corporate formations under ยง 351.
C) The transfers of stock to and from shareholders qualify for like-kind exchange treatment.
D) The value of the stock received by the shareholder less the gain not recognized (postponed) will equal the shareholder's basis in the stock received.
E) All of the above statements are true.

F) A) and D)
G) A) and E)

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