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Comprehensive Problem $16-63($LO $16-1,$ LO $16-2,$ LO $16-3,$ LO $16-4,$ LO $16-5,$ LO $16-6)($Algo$)$

$[$The following information applies to the questions displayed below$]$

Carrie D'Lake, Reed A$.$ Green, and Doug A$.$ Divot share a passion for golf and decide to go into the golf club

manufacturing business together. On January $2,2023,$ D'Lake, Green, and Divot form the Slicenhook Partnership, a

general partnership. Slicenhook's main product will be a perimeter$-$weighted titanium driver with a patented graphite shaft.

All three partners plan to actively participate in the business. The partners contribute the following property to form

Slicenhook:

Partiner

Contribution

Carrie D'Lake

Land, FIN

$$479,000$

Reed A$.$ Green

Basis $$479,000,$ Mortgage

$$79,090$

Cash

$$400,000$

$$400,000$

Doug A$.$ Oivot

Cash

Carrie had recently acquired the land with the idea that she would contribute it to the newly formed partnership. The

partners agree to share in profits and losses equally. Silcenhook elects a calendar year$-$end and the accrual method of

accounting.

In addition, Silcenhook received a $$1\mathrm{.}728,000$ recourse loan from Big. Bank at the time the contributions were made.

Slicenhook uses the proceeds from the loan and the cash contributions to build a state$-$of$-$the$-$art manufacturing facility

$($ $$1,295,000),$ purchase equipment $($ $$657,000),$ and produce inventory $($ $$438,000).$ With the remaining cash, Slicenhook

invests $$64\mathrm{.}000$ in the stock of a privately owned graphite research company and retains $($ $$74\mathrm{.}000)$ as working cash.

Slicenhook operates on a just$-$in$-$time inventory system, so it sells all inventory and collects all sales immediately. That

means that at the end of the year, Silcenhook does not carry any inventory or accounts receivable balances. During $2023$

Slicenhook has the following operating results:

Sales

Cost of goods sold

Interest income from tax$-$exempt bonds

Qualified dividend income from stock

Operating expenses

Depreciation $($tax$)$

$$179$ on equipment

Equipment

$$1,202,000$

$432,720$

$1,090$

$2,070$

$145,000$

$182,000$

$310,000$

Building

Interest expense $on$ debt

The partnership is very successful in its first year. The success allows Slicenhook to use excess cash from operations to

purchase $$72,000$ of tax$-$exempt bonds $($you can see the interest income already reflected in the operating results$).$ The

parthership also makes a princlpal payment on its loan from Big Bank in the amount of $$300,000$ and a distribution of

$$100,000$ to each of the partners on December $31,2023.$

The partnership continues its success in $2024$ with the following operating results:

The operating expenses include a $$2,750$ trucking fine that one of its drivers incurred for reckless driving and speeding

and meals expense of $$6,000($the meals were not provided by a restaurant$).$

By the end of $2024,$ Reed has had a falling out with Carrie and Doug and has decided to leave the parthership. He has

located a potential buyer for his partnership interest, Indie Ruff. Indie has agreed to purchase Reeds interest in Sicenthook

for $$1,034,000$ in cash and the assumption of Reed's share of Slicenhook's debt: Carrie and Doue however are not certain

that admitting Indie to the partnership is such a good idea. They want to consider having Slicenhook liquidate Reed's

interest on January $1,2025.$ As of January $1,2025,$ Slicenhook has the following assets:

Carrie and Doug propose that Slicenhook distribute the following to Reed in complete liquidation of his partnership

interest:

Slicenhook has not purchased or sold any equipment since its original purchase just after formation.

Required:

$($a$)$ What are Carrie's, Reed's, and Doug's bases in their partnership interest at the end of $2023$ and $2024?$

$($b$)$If Reed sells his interest in Slicenhook to Indie Ruff, what are the amount and character of his recognized gain or loss?

$($c$)$ What is Indie's basis in the partnership interest?

$($d$)$ If Reed sells his interest in Slicenhook to Indie Ruff, what is Indie's inside basis in Slicenhook?

$($e$)$ What effect would a section $754$ election have on Indie's inside basis?

f$)$ If Slicenhook distributes the assets proposed by Carrie and Doug in complete liquidation of Reed's partnership interest, what are the amount and character of Reed's recognized gain or loss?

I$($g$)$ If Slicenhook distributes the assets proposed by Carrie and Doug in complete liquidation of Reed's partnership interest, what is Reed's basis in the distributed assets?