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. Z owns a rental building (its only asset) with a gross fair market value of $5

ID: 2450521 • Letter: #

Question

. Z owns a rental building (its only asset) with a gross fair market value of $5,000 subject to the non-recourse mortgage of $2,000. Z’s adjusted basis for this building is $1,500. All of Z’s stock is owned by C, whose basis for his stock in Z is $500. Z had 1,000 of E&P. Z is on the accrual method of accounting and reports on the calendar year. Assume that the corporate tax payable by Z on $3,500 gained is$1250 and on $3,000 gained is $1,000. D agrees to pay Z an additional contingent amount for the building in order to induce Z to sell. The gross fair market value of Z’s property is actually $5,000. D also agrees to give a Z “contingent” right to receive from D an additional $2,500 over 10 years if D earns profits from the building in excess of profits historically earned.

a. If the transaction is held open, Z will recognize $3,500 gain on the sale.

b. Upon collecting additional amounts from D, C will recognize additional capital gain.

c. Upon collecting additional amounts from D, Z might also be expected to recognize additional gain, although Bittker& Eustice apparently take a contrary position.

d. None of the above.

e. All of the above, except D.

please explain why you choose this answer.

Explanation / Answer

b. Upon collecting additional amounts from D, C will recognize additional capital gain.

When the additional amount that is promised by D will be received by C, it will be treated as the consideration for the building and it will be treated as capital gain and taxable accordingly.