Answer the following questions regarding four liquidating distribution scenarios, the partnership also liquidates. If there is no
Question:
Answer the following questions regarding four liquidating distribution scenarios, the partnership also liquidates.
If there is no gain or loss or if an amount is zero, enter "0".
a. For each, determine the amount and character of any gain or loss to be recognized by each partner and the basis of each asset (other than cash) received.
Assume for all scenarios that the distributions of hot assets are proportionate to the partners (or there are no hot assets). You can use the format in Concept Summary 11.4.
(1) Zaara has a partnership basis of $90,000 and receives a distribution of $112,500 in cash.
He will recognize of $fill in the blank .
(2) Mark has a partnership basis of $112,500. He receives $45,000 cash and a capital asset with a basis to the partnership of $56,250 and a fair market value of $90,000.
He will recognize of $fill in the blank _2. His basis in the capital asset is $fill in the blank
(3) Neil has a partnership basis of $225,000. He receives $90,000 cash, inventory with a basis to the partnership of $67,500, and a capital asset with a partnership basis of $45,000. The inventory and capital asset have fair market values of $45,000 and $67,500, respectively.
He will recognize of $fill in the blank a_2. The capital asset is allocated a basis of $fill in the blank and the inventory will have a basis of $fill in the blank a
(4) Oscar has a partnership basis of $90,000. He receives a distribution of $22,500 cash and an account receivable with a basis of $0 to the partnership (value is $34,200).
He will recognize a of $fill in the blank .
b. In each of the four situations in part (a), are any planning techniques available to the partnership to avoid any “lost basis” results?
For any of the four situations, students might answer “make a § 754 election.”. However, because the partnership is liquidating, this viable.
c. In the four situations in part (a), would your answers change if the transaction had been a current distribution?
The results for transaction (1) change since gain recognition rules are the for both current and liquidating distributions.
For transactions (2) and (3), the bases of capital assets be adjusted in Step 3 of a current distribution.
In situations (2) to (4), there gains, losses, or basis adjustments in a current distribution, so adjustment is needed.
Income Tax Fundamentals 2013
ISBN: 9781285586618
31st Edition
Authors: Gerald E. Whittenburg, Martha Altus Buller, Steven L Gill