Contemporary Tax Practice Cover   Contemporary Tax Practice
Research, Planning and Strategies
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John O. Everett, Ph.D., CPA
Cherie J. Hennig, Ph.D., M.B.A.
Nancy Nichols, Ph.D., CPA

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Contemporary Tax Practice
Tax Tutorial Module 3 — C Corporation Taxation - Operations
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Topic 1: C Corporations – Gross Income, Exclusions and Capital Gains and Losses
[IRS Materials: Publication 542 and 544]


A. Stock Transferred in Satisfaction of Debt

1. Occasionally a corporation will transfer some of its stock to creditors in satisfaction of indebtedness. In such a case, the corporation is treated as satisfying the debt in full with money equal to the fair market value of the stock

2. As a result of this assumed equivalence with cash, the corporation will have cancellation of indebtedness income to the extent that the debt exceeds the value of the stock, unless the company is bankrupt, insolvent, or the transfer is on qualified debt on business realty.

Example – Tee Company transferred stock with a par value of $20,000 and a fair market value of $18,000 to Zee Company in full payment of a business debt of $22,000. In this case, Tee must report cancellation of indebtedness income of $4,000 ($22,000 debt cancelled less $18,000 fair market value of stock transferred).



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