Question: The ABC partnership has three equal partners, A, B, and C, and the following balance sheet: Assets Partner's Capital Adj. Basis FMV Adj. Basis FMV

The ABC partnership has three equal partners, A, B, and C, and the following balance sheet:

AssetsPartner's Capital
Adj. BasisFMVAdj. BasisFMV
Cash60,00060,000A70,00080,000
Cap Asset 190,00060,000B70,00080,000
Cap Asset 240,00060,000C70,00080,000
Cap Asset 320,00060,000
210,000240,000210,000240,000

A receives capital asset #1 in an operating distribution. A has a one-ninth interest worth $20,000 in the partnership capital and profits after the distribution.

(a) What results to A and the partnership if there is no §754 election? Reconstruct the balance sheet after the distribution.

(b) What results to A and the partnership if the partnership has made a §754 election? Reconstruct the balance sheet after the distribution.

(c) How should any basis adjustment be allocated among the partners?

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