Question: 4 . A , B and C form a general partnership with cash contributions of $ 5 0 , 0 0 0 , $ 5

4. A, B and C form a general partnership with cash contributions of $50,000, $50,000 and $100,000, respectively. The partnership agreement provides for the maintenance of proper capital accounts in accordance with Treas. Reg. Sec. 1.704-1(b)(2)(iv) and that capital accounts are to be liquidated in accordance with positive capital account balances. Each partner has an unconditional obligation to restore any deficit balance in their capital account upon liquidation. The partnership borrows $1,000,000 on a recourse basis and acquires an apartment building for $1,000,000. For the next three years, the partnership operates the apartment building at an annual loss of $40,000, not including depreciation, which is an additional $40,000 per year. The partnership agreement provides that all items of income, gain, loss, deduction and credit will be allocated 25% to A and B and 50% to C, except for depreciation, which will be allocated entirely to C. At the end of three years, what are the cumulative amounts of operating loss and depreciation properly allocated to the three partners? What is each partners capital account balance at the end of the third year? Please fully explain the allocations for each year based on your analysis of the rules under Sec. 704(b).(10 points)

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