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Tax 2 case study regarding income tax consequences for property exchanged for stock

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Jeff owns a small successful restaurant. He want to expand but need a second location.  He think his business has a FMV of $2,000,000 (and has a basis of $500,000 to Jeff).  The business is currently an LLC. Thomas is a real estate broker and investor.  He normally buys real estate and sells it quickly.  

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