Question: Given: B.B. Co., an LLC that is taxed as a partnership with equal members Ruth, DiMaggio, Jackson and Berra. Ten years ago, the company took

Given: B.B. Co., an LLC that is taxed as a partnership with equal members Ruth, DiMaggio, Jackson and Berra. Ten years ago, the company took out a nonrecourse loan of $5,200,000 and purchased a building for $5,000,000. The building has a depreciable life of 39.5 years and has been depreciated for ten years; the current accumulated depreciation total is $1,265,823. The partnership agreement calls for a 10% preferred return on capital contributions, and currently no original capital has been distributed. The company currently has $250,000 cash, land worth $1,000,000 and other assets worth $50,000. There are no differences between the book and tax values of any assets.

The partnership admits a new partner, Jeter. Jeter invests $3,000,000 and guarantees the partnership's debt in exchange for a 20% interest.

The partnership undergoes a revaluation under IRC section 704(b).

B.B., LLC's balance sheet prior to admittance of Jeter:

Assets
Cash 250,000
Building 5,000,000
Acc. Depreciation (1,265,823)
Land 1,000,000
Other Assets 50,000
Liabiities
Bank Loan (5,200,000)
Equity
Ruth Contributions (450,000)
Ruth Distributions 500,000
Ruth Income Allocation (8,544)
DiMaggio Contributions (450,000)
DiMaggio Distributions 500,000
DiMaggio Income Allocation (8,544)
Jackson Contributions (450,000)
Jackson Distributions 500,000
Jackson Income Allocation (8,544)
Berra Contributions (450,000)
Berra Distributions 500,000
Berra Income Allocation (8,545)

Determine the following:

What will the new balance sheet look like that includes Jeter as a member and uses the remedial method of debt allocation under IRC Sec. 704(c)?

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