Which of the following is a characteristic of U.S. District Courts?
a. A District Court is a national court that hears cases from taxpayers anywhere in the
U.S.
b. The District Court judges are tax specialists who hear only tax cases.
c. A taxpayer need not pay any alleged deficiency in order to bring an action against the
IRS.
d. The taxpayer may obtain a jury trial; the jury decides matters of fact but not matters
of law.
Sergio and Chris agree to combine their sole proprietorships and form a corporation.
Sergio will contribute cash of $20,000 and business property worth $120,000 (adjusted
basis of $50,000) for a 25% interest. Chris will contribute cash of $200,000 and
business property worth $220,000 (adjusted basis of $200,000) for a 75% interest.
Which of the following statements concerning the tax treatment of Sergio and Chris’s
exchange of assets is/are correct?
I. Because neither owner owns more than 80% of the stock in the corporation, the
transfers do not qualify for tax-free treatment.
II. Based on the wherewithal-to-pay concept, each owner is taxed on the cash they
contributed to the corporation.
III. Sergio will recognize a $70,000 gain and Chris will recognize a $20,000 gain.