- 16 - Standard Insurance Note, for satisfaction of the debt. The same is true for the Bunn & Duran obligation. The fact that petitioners remained liable on the Standard Insurance and Bunn & Duran debts does not alter their section 357(c) liability under the rationale of Owen. For the above reasons, we hold that petitioners are required to recognize gain under section 357(c)(1), measured by the excess of the debt obligations secured by the three parcels of real property at the time of the transfer to NAC Corporation over petitioners' total adjusted basis in the property. To reflect this holding, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011