Vincent is a 50% partner in the TAV Partnership. He became a partner three years ago when
Question:
Vincent is a 50% partner in the TAV Partnership. He became a partner three years ago when he contributed land with a value of $60,000 and a basis of $30,000 (current value is $100,000). Tyler and Anita each contributed $30,000 cash for a 25% interest. Vincent's basis in his partnership interest is currently $150,000; the other partners' bases are each $75,000. The partnership has the following assets:
| Basis | FMV |
Cash | $200,000 | $200,000 |
Accounts receivable | 0 | 200,000 |
Marketable securities | 70,000 | 100,000 |
Land | 30,000 | 100,000 |
Total | $300,000 | $600,000 |
In general terms, describe the tax result if TAV distributes a $50,000 interest in the land each to Tyler and Anita and $100.000 of accounts receivable to Vincent at the end of the current year. Calculations are not required.
2) Assume the same facts as in Problem 1, except that TAV distributes $100,000 of cash to Vincent, $50,000 of marketable securities to Tyler, and $50,000 of accounts receivable to Anita. In general, terms, describe the tax result of the distribution.
3) Assume the same facts as Problem 1, except that TAV distributes a $50,000 interest in the land and $50,000 of accounts receivable to Vincent, and $25,000 of cash and $25,000 of accounts receivable each to Anita and Tyler. In general, terms, describe the tax result of the distribution.
4) Use the assets and partners' bases from Problem 1. Assume the partnership distributes all its assets in a liquidating distribution. In deciding the allocation of assets, what issues should the partnership consider to minimize each partner's taxable gains?
South Western Federal Taxation 2016 Corporations Partnerships Estates and Trusts
ISBN: 9781305399884
39th edition
Authors: James Boyd, William Hoffman, Raabe, David Maloney, Young