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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