Birch Corp., a calendar-year corporation, was formed three years ago by its sole shareholder, James, who has operated it as an S corporation since its inception. Last year, James made a direct loan to Birch Corp. in the amount of $6,650. Birch Corp. has paid the interest on the loan but has not yet paid any principal. (Assume the loan qualifies as debt for tax purposes.) For the year, Birch experienced a $32,000 business loss.

What amount of the loss clears the tax basis limitation, and what is James?s basis in his Birch Corp. stock and Birch Corp. debt in each of the following alternative scenarios?

a. At the beginning of the year, James's basis in his Birch Corp. stock was $46,100 and his basis in his Birch Corp. debt was $6,600.
b. At the beginning of the year, James's basis in his Birch Corp. stock was $10,300 and his basis in his Birch Corp. debt was $6,600.
c. At the beginning of the year, James's basis in his Birch Corp. stock was $0 and his basis in his Birch Corp. debt was $6,600.

A. Based on the information given All the $32,000 amount of the loss will clear up the tax basis limitation which means that James’s stock basis will be reduced to $14,100 ($46,100 – $32,000 loss) while His debt basis on the other hand remains at $6,600.

Therefore:

$32,000 clears the tax basis limitation

$14,100 basis in his Birch Corp. stock

$6,600 Birch Corp. debt

B. Based on the information given of the $32,000 loss, $16,900($10,300+$6,600) will clear up the tax basis limitation, While his stock basis will be reduced from $10,300 to $0, and his debt basis will be reduced from $6,600 to $0. Which means that he has a suspended loss of $15,100 ($32,000 - $16,900)

Therefore:

$16,900 clears the tax basis limitation

$0 basis in his Birch Corp. stock

$0 Birch Corp. debt

$15,000 suspended loss

C. Based on the information given the amount of $6,600 will clear up the tax basis limitation. His stock basis will remains at $0, while his debt basis will be reduced from $6,600 to $0. Which means that he has a suspended loss of $25,400 ($32,000 – $6,600)

Therefore:

$6,600 clears the tax basis limitation

$0 basis in his Birch Corp. stock

$0 Birch Corp. debt

$25,400 suspended loss