Transfer of Property and Services to a Controlled Corporation. In 2010, Ed, Fran, and George form Jet Corporation. Ed contributes land having a $35,000 FMV purchased as an investment in 2006 for $15,000 in exchange for 35 shares of Jet stock. Fran contributes machinery (Sec. 1231 property) purchased in 2006 and used in her business in exchange for 35 shares of Jet stock. Immediately before the exchange, the machinery had a $45,000 adjusted basis and a $35,000 FMV. George contributes services worth $30,000 in exchange for 30 shares of Jet stock.
a. What is the amount of Ed's recognized gain or loss?
b. What is Ed's basis in his Jet shares? When does his holding period begin?
c. What is the amount of Fran's recognized gain or loss?
d. What is Fran's basis in her Jet shares? When does her holding period begin?
e. How much income, if any, does George recognize?
f. What is George's basis in his Jet shares? When does his holding period begin?
g. What is Jet's basis in the land and the machinery? When does its holding period begin?
How does Jet treat the amount paid to George for his services?
h. How would your answers to Parts a through g change if George instead contributed $5,000 in cash and services worth $25,000 for his 30 shares of Jet stock?