Problem
Miley will contribute $1,000,000 cash to the venture and McLovin will contribute a building that has a $1,000,000 fair market value and adjusted basis of $400,000. Initially Miley thinks she wants to pay McLovin's $500,000 for a 50% interest in the building so she owns half of the building before they form the corporation.
The decide they want to make a S- Election. What is the timing for the election, shareholder requirements, and potential built-in gains tax.