Lonnie Davis has been a general partner in the Highland Partnership for many years and is also a sole proprietor in a separate business. To spend more time focusing on his sole proprietorship, he plans to leave Highland and will receive a liquidating distribution of $50,000 in cash and land with a fair market value of $100,000 (tax basis of $120,000). Immediately before the distribution, Lonnie's basis in his partnership interest is $350,000 which includes his $50,000 share of partnership debt. The Highland Partnership does not hold any hot assets.
a. What is the amount and character of any gain or loss to Lonnie?
b. What is Lonnie's basis in the land?
c. What is the amount and character of Lonnie's gain or loss if he holds the land for thirteen months as investment property and then sells it for $100,000?
d. What is the amount and character of Lonnie's gain or loss if he places the land into service in his sole proprietorship and then sells it thirteen months later for $100,000?
e. Do your answers to parts c. and d. above suggest a course of action that would help Lonnie to achieve a more favorable tax outcome?