Amount and character of the gain

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Reference no: EM13954792

ParentCo sells street vending carts and has been in business for 10 years. The subsidiary, SubCo, has been in the business of selling refrigerated vending carts for 8 years. You are a 50% partner of ParentCo with Able. The basis of your shares is $80,000 while Able's basis is $60,000. On April 10, 20x1, ParentCo allocated 100% of SubCo stock to shareholder Able in exchange for the Able's ParentCo shares. Able's ParentCo shares are subsequently cancelled. There is a bona fide business purpose for this exchange. At the end of 20x1, ParentCo has $150,000 of E&P. The fair market value of ParentCo stock is $3,000/share and the fair market value of SubCo is $1,000/share.

What is the amount and character of the gain, loss or income that must be recognized by you as a result of the distribution of the SubCo stock?
What is the amount and character of the gain, loss or income that must be recognized by ParentCo as a result of the distribution of the SubCo stock?
What is Able's basis in the SubCo's stock?
When will Able's holding period for the SubCo stock begin?

Reference no: EM13954792

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