Gabriella and Juanita form Luster Corporation. Gabriella transfers cash of $50,000 for 50 shares of stock, while Juanita transfers information concerning a proprietary process (basis of zero and fair market value of $50,000) for 50 shares of stock
a. The transfers to Luster are fully taxable to both Gabriella and Juanita.
b. Juanita must recognize gain of $50,000.
c. Because Juanita is required to recognize gain on the transfer, Gabriella also must recognize gain.
d. Neither Gabriella nor Juanita will recognize gain on the transfer.
e. None of the above.
d
RATIONALE: The transfers are nontaxable to both Gabriella and Juanita. Each of them qualifies as a property transferor and together control the corporation. Therefore, the transfer is subject to tax deferred treatment under ยง 351.
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