On September 18, 2021, Paul, Rose & Susan form the PRS general partnership in which each has the same one-third interest in the partnership's capital and profits/losses.

Paul will contribute Property #1 with an FMV of $380,000 and an AB of $240,000. At the time of the contribution, Property #1 was encumbered by a $180,000 nonrecourse liability. Rose and Susan each contribute $150,000 of cash (a total of $300,000) to the partnership. Assume that Paul's net liability relief is deemed to be $120,000 ($180,000 752(b) relief minus $60,000 752(a) share) and that Paul receives a $50,000 check from the PRS partnership upon the formation of the partnership.

What is (i) the amount of gain Paul must recognize as a result of the transfer, (ii) the partnership's the inside basis in Property #1, (iii) Paul's capital account balance, and (iv) Paul's outside basis in his partnership interest, under the following independent assumptions:

a) Paul incurred the liability encumbering Property #1 on October 13, 2020.

b) Paul incurred the liability encumbering Property #1 on June 1, 2016.

Answer rating: 100% (QA)

a Paul must recognize a gain of 80000 on the transfer of Property 1 to the partnership The partnersh... View the full answer