Juanita Gordon received a total cash buyout of $300,000 in liquidation of her one-third interest in Carmageddon

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Juanita Gordon received a total cash buyout of $300,000 in liquidation of her one-third interest in Carmageddon Partners. Her tax basis in the liquidated interest was $125,000.

Of the total amount received, $100,000 was attributable her share of the partnership's unrealized accounts receivable and $50,000 to her share of partnership goodwill. Capital is not a material income-producing factor for the partnership, and the partnership agreement does not require that partners be compensated for their shares of partnership goodwill upon retiring from the partnership.

a. How much ordinary income will Juanita recognize on receipt of the buyout?

b. How much capital gain will Juanita recognize?

c. Assume that Juanita received the buyout payments over 5 years. If she received

$60,000 this year (the year of her retirement), how much (if any) of that distribution will be taxable as ordinary income and how much as capital gain?

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CCH Federal Taxation Basic Principles 2020

ISBN: 9780808051787

2020 Edition

Authors: Ephraim P. Smith, Philip J. Harmelink, James R. Hasselback

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