Question

Three individuals form Skylark Corporation with the following contributions: Cliff, cash of $50,000 for 50 shares; Brad, land worth $20,000 (basis of $11,000) for 20 shares; and Ron, cattle worth $9,000 (basis of $6,000) for 9 shares and services worth $21,000 for 21 shares.

A. Ron’s basis in his stock is $6,000
B. Brad’s basis in his stock is $20,000
C. Ron’s basis in his stock is $27,000
D. These transfers are fully taxable and not subject to § 351.
E. Ron has income on the transaction of $20,000.

Answer 1

C. Ron’s basis in his stock is $27,000

Step-by-step explanation:

Income recognized on services rendered $21,000

Add basis of $6,000

Ron stock basis $27,000

The property contributed by Ron is not considered insignificant compared to the value of the services he has rendered, which is why the entire contribution is counted as being for property.

Hence, the control requirement is satisfied and a valid § 351 transaction results. Ron’s stock basis is $27,000 [$6,000 (basis of cattle transferred) + $21,000 (income recognized on services rendered)]