Kevan, Jerry, and Dave formed Albee LLC. Jerry and Dave each contributed $245,000 in cash. Kevan contributed the following assets:
Kevan: _______________Basis Fair __________Market Value
Cash..........................$ 15,000 ...................... $ 15,000
Land* ........................120,000 .......................440,000
Totals ........................$ 135,000 ....................$ 455,000
*Nonrecourse debt secured by the land equals $210,000
Each member received a one-third capital and profits interest in the LLC.
a. How much gain or loss will Jerry, Dave and Kevan recognize on the contributions?
b. What is Kevan's tax basis in his LLC interest?
c. What tax basis do Jerry and Dave have in their LLC interests?
d. What is Albee LLC's tax basis in its assets?
e. Following the format in Exhibit 20-2, prepare a tax basis balance sheet for the Albee LLC showing the tax capital accounts for the members. What is Kevan's share of the LLC's inside basis?
f. If the lender holding the nonrecourse debt secured by Kevan's land required Kevan to guarantee 33.33 percent of the debt and Jerry to guarantee the remaining 66.67 percent of the debt when Albee LLC was formed, how much gain or loss will Kevan recognize?
g. If the lender holding the nonrecourse debt secured by Kevan's land required Kevan to guarantee 33.33 percent of the debt and Jerry to guarantee the remaining 66.67 percent of the debt when Albee LLC was formed, what are the members' tax bases in their LLC interests?