Question: PROBLEM D is a one - third general partner in the DEF partnership. Both D and the partnership are cash method, calendar year taxpayers. D

PROBLEM D is a one-third general partner in the DEF partnership. Both D and the partnership are cash method, calendar year taxpayers. D dies at a time when the partnership has earned $15,000 for the current year, and his share of the untaxed and undistributed partnership income for the year is $5,000. Under all of the sale or liquidation agreements described below, D is to be paid $30,000 for his interest, which includes his share of current-year income. At the time of D's death, and before making any adjustments on account of the operating income generated during the current year, the DEF partnership has the following balance sheet: Assets Assume, alternatively, that D's interest: (1) passes to his estate; (2) is subject to a buy-out agreement at his death; (3) is liquidated by the partnership (which is a services partnership); or (4) is liquidated by the partnership in which capital is a material income-producing factor. Under each alternative, consider the following questions: (a) Does the partnership's taxable year close as to D's estate? (b) What is the amount included in D's gross estate? (c) To what extent does the interest included in D's gross estate constitute income in respect of a decedent? (d) what outside basis does D's estate take in the partnership interest immediately following D's death?
PROBLEM D is a one - third general partner in the

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