A owns 50% of the ABC general partnership. The remaining 50% is owned equally by B and
Question:
A owns 50% of the ABC general partnership. The remaining 50% is owned equally by B and C. The partnership made a § 754 election. Prior to any distributions, A's outside basis is $550. On January 1, 2004, ABC distributes Land with a value of $400 in complete liquidation of her interest in the partnership. At the time of the liquidating distribution the partnership's balance sheet (after booking up) is as follows:
Assets Liabilities & Capital
Basis Book Liabilities
Inventory $100 $240 Mortgage $900
Land 250 400
Building 750 1060
Total $1100 $1700 Capital Accounts
Tax Book
A $100 $400
B 50 200
C 50 200
Total $200 $800
Questions:
a. What is the amount and character of any gain or loss recognized by each of the parties as a result of this transaction?
b. What is A's basis in the land received in the transaction?
c. What is the partnership's basis in the inventory and the building after the transaction?
Income Tax Fundamentals 2013
ISBN: 9781285586618
31st Edition
Authors: Gerald E. Whittenburg, Martha Altus Buller, Steven L Gill