Alicia and Bart are the sole shareholders of X Corporation, which is engaged in a financial services business. Alicia and Bart each own 50 shares of common stock. Alicia contributed a § 453 installment note with a basis of $20,000 and a fair market value of $100,000 to X Corporation in exchange for 10 shares of stock worth $100,000. Alicia received the note earlier this year for land that she had held for investment for many years. Bart, who has a real estate license but does not actively conduct any real estate brokerage business contributed a cash method account receivable in the amount of $15,000, which arose from brokering a commercial lease on behalf of a friend who owned an office building. Bart also contributed a parcel of land held for sale to customers in the ordinary course of his unincorporated real estate development business, which had a basis of $20,000 and a fair market value of $85,000, and which was subject to a binding executory purchase and sale contract. In exchange, Bart received in exchange 10 shares of stock worth $100,000. What are the tax consequences to Alicia, Bart and X Corporation as a result of the formation of the corporation?
