Problem
On January 4, 2016, Martin Corporation acquires two properties from a shareholder in a transaction that qualifies under § 351. The shareholder's basis, the fair market value, and the built-in gain (loss) of each property are:
Shareholder's Basis Fair Market Value Built-In Gain (Loss)
Property 1 $300,000 $375,000 $ 75,000
Property 2 525,000 400,000 (125,000)
Net built-in loss ($ 50,000)
Martin adopts a plan of liquidation later in the year and distributes Property 2 to a 30% shareholder when the property is worth $350,000.
a. Compute Martin's basis in Property 1 and in Property 2 as of January 4, 2016.
b. Compute Martin's realized and recognized loss on the liquidating distribution of Property 2.