Question: On January 1 , 2 0 2 2 , Steve, Sarah, and Seth formed the SSS Ltd . , a general partnership. The following contributions

On January 1,2022, Steve, Sarah, and Seth formed the SSS Ltd., a general partnership. The following contributions were made by the partners: Steve contributed land with a FMV of $1,175,000, an adjusted basis of $250,000 and a recourse (bank loan) debt of $275,000. The recourse debt was from a bank that Steve owned 5%, his parents owned 15%, and his grandparents owned 35% with the balance owned by unrelated employees of the bank. Sarah contributed cash of $400,000, equipment with a FMV of $700,000, an adjusted basis of $900,000, and a nonrecourse (bank loan) debt of $200,000. The nonrecourse debt was from a bank that is 60% owned by Sarahs grandparents, 10% by Sarah, and 15% by Sarahs parents. The balance of the bank is owned by individuals unrelated to Sarah. The equipment has 4.5 years of depreciation left, $200,000 per year for tax purposes. The asset was a 7-year class asset. MACRS straight-line depreciation was elected for the equipment when it was placed in service by Sarah. Seth contributed an apartment building and land with a FMV of $1,600,000(building $1,350,000 and land $250,000), an adjusted basis of $481,800(building $376,525 and land $105,275) and a nonrecourse (bank loan) debt of $1,000,000. The building and land were purchased on March 1,2015, for $605,295(building $500,000 and land $105,295).The bank is unrelated to Seth. The partners will share profits and losses in the same ratio as their initial capital contributions using the partners interest in the partnership found in Regs. 1.704-1(b)(3). SSS Ltd. is a calendar year accrual basis partnership. The nonrecourse debt contributed by Seth should be allocated: Group of answer choices Steve $333,333; Sarah $333,333; Seth $333,334 Steve $180,675; Sarah $180,675; Seth $638,650 Steve $0; Sarah $0; Seth $1,000,000 Steve $375,000; Sarah $375,000, Seth $250,000

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