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While purchasing insurance solely in the name of the entity appears to solve this coverage gap, this may leave the transferor vulnerable to loss. 1001-1(e), where a property transfer is part sale and part gift, the transferor has a gain to the extent that the amount realized exceeds the property's adjusted basis. 74-503--including whether the transferor and the transferee each have zero basis in stock received in the exchange--are "under study" by the IRS. |
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