Distribute all of the land to Maria.

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June 4, 2020

Distribute all of the land to Maria.

23. LO.1, 4 Pink Corporation acquired land and securities in a § 351 tax-free exchange in 2011. On the date of the transfer, the land had a basis of $720,000 and a fair market value of $1 million, and the securities had a basis of $110,000 and a fair market value of $250,000. Pink Corporation has two shareholders, Maria and Paul, who are unrelated. Maria owns 85% of the stock in the corporation, and Paul owns 15%. Pink adopts a plan of liquidation in 2012. On this date, the value of the land has decreased to $500,000. What is the effect of each of the following on Pink Corporation? Which option should be selected? 

a. Distribute all of the land to Maria. 

b. Distribute all of the land to Paul. 

c. Distribute 85% of the land to Maria and 15% to Paul. 

d. Distribute 50% of the land to Maria and 50% to Paul. 

e. Sell the land and distribute the proceeds of $500,000 proportionately to Maria and to Paul. 

24. LO.1, 4 Assume in Problem 23 that the land had a fair market value of $630,000 on the date of its transfer to the corporation. On the date of the liquidation, the land’s fair market value has decreased to $500,000. How would your answer to Problem 23 change if: 

a. All of the land is distributed to Maria? 

b. All of the land is distributed to Paul? 

c. The land is distributed 85% to Maria and 15% to Paul? 

d. The land is distributed 50% to Maria and 50% to Paul? 

e. The land is sold and the proceeds of $500,000 are distributed proportionately to Maria and to Paul?